2018
02.04

IN THE COURT OF COMMON PLEAS MONTGOMERY COUNTY PENNSYLVANIA
CRIMINAL DIVISION

COMMONWEALTH OF PENNSYLVANIA #3151-15
  #MJ-38118-CR-0000096-2015
v.  
  Superior Court
Terance Healy #3166 EDA 2015
  #3234 EDA 2015
  #376 EDA 2016
   
  Supreme Court of Pennsylvania
  #126 MAL 2017


EMERGENCY MOTION TO STRIKE FALSE DOCUMENTS PDF version

TO THE HONORABLE JUDGES OF THE COURT OF COMMON PLEAS:

Defendant, Terance Healy, petitions this court as witness and requests actions to provide immediate relief from two documents provided to him through his mother on Friday, February 2, 2018 and having been personally delivered to his mother by Philip D. Press, Esquire.

Document 1.
MOTION OF STANDBY COUNSEL, et al, (Attached).

This document falsely and incorrectly states that ‘On or about October 22, 2009, the Defendant was arrested and charged with murder and associated charges.”

The sentence is slanderous, libelous and could place the safety of the Defendant in immediate danger.

Document 2 was issued in support of the false and incorrect information.
COMMONWEALTH’S MOTION TO AMEND BILLS OF INFORMATION

Paragraph Number 2 is incomplete. It reads as follows:
“2. The affadavit of probable cause and subsequent discovery outlines a series of”

Paragraph Number 3 amends the Bill of Information to include four (4) counts of Harassment, 2709(a)(3), graded as summaries.

Paragraph Number 3(a) indicates:
“A person commits the crime of harassment when, with intent to harass, annoy or alarm another, the person… (3) engages in a course of conduct of repeatedly committed acts which serve no legitimate purpose.”

If these false statements, “which serve no legitimate purpose” are intended as a joke, then clearly it has failed. Instead, it is cruel. It causes a dread fear for the possibility of being placed in a shoot first situation with police acting on the grossly incorrect information.

Rule 564. Amendment of Information.
The court may allow an information to be amended, provided that the information as amended does not charge offenses arising from a different set of events and that the amended charges are not so materially different from the original charge that the defendant would be unfairly prejudiced. Upon amendment, the court may grant such postponement of trial or other relief as is necessary in the interests of justice.

Sentence 6 continues with the farce by suggesting the Defendant was aware of the false information which is included in the document. The statement is entirely untrue.
“The proposed amendments do not allege a set of facts which were unknown to the Defense; instead, the Defense had notice of the allegations of the Commonwealth since October of 2009. Therefore the proposed amendments do not affect possible defenses that may be available at time of trial.”

Defendant respectfully requests that ANY JUDGE OF THE COURT OF COMMON PLEAS of MONTGOMERY COUNTY take appropriate actions to promptly STRIKE the false documents before the Defendant is executed based on actions relating to this grossly false information.

Defendant demands the immediate removal of Philip D. Press, Esquire from any assignment or responsibility to the Defendant in the interest, where his actions seek to harm the Defendant and his assignment not supported by the proceedings which it purports to reference.

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

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