MOTION TO COMPEL PRODUCTION OF COMPLETE COURT RECORD

IN THE SUPERIOR COURT OF PENNSYLVANIA

Sonya Healy	: Superior Court of Pennsylvania
(Appellee)	: 1330 EDA 2013
	:
v.	:
	:
Terance Healy	:
(Appellant)	:

MOTION TO COMPEL PRODUCTION OF COMPLETE COURT RECORD

COUNT ONE:
FAILURE TO DELIVER THE COMPLETE RECORD OF THE MATTER

1. Pursuant to the Rules of Appellate Procedure, the Prothonotary of Montgomery County, Pennsylvania was directed to provide the record for this matter being appealed before the Superior Court.

2. The Prothonotary failed to prepare and deliver the record by the date directed by the Superior Court. (June 28, 2013)

3. The Prothonotary has failed to deliver the complete record to the Superior Court.

4. The Service List of Record Documents transmitted by Mark Levy, Prothonotary on July 8 2013 includes reference numbers where documents have NOT been delivered.

5. The Service List of Record Documents transmitted lists documents which have not been delivered to the Superior Court on July 8, 2013 or July 11, 2013.

COUNT TWO:
FAILURE TO PRODUCE THE TRANSCRIPTS FOR THE MATTER

6. Transcripts related to hearings on the matter have not been prepared and delivered to the Superior Court.

7. Requests for the Production of Transcripts pursuant to the Rules of Appellate Procedure were requested (1) concurrent with the filing of the Notice of Appeal; (2) updated on May 15, 2013; (3) resubmitted on May 22, 2013.

8. Court Reporters have neglected to prepare and deliver the Transcripts as required by the Rules of Appellate Procedure.

COUNT THREE:
INCOMPLETE TRANSCRIPTS ARE MISSING REFERENCED EXHIBITS

9. Transcripts which have been provided are missing referenced Exhibits.

10. This omission has been presented to the Court Reporters and the Court Reporters Office in Norristown. There has been no response or action regarding the missing documents.

Whereas, the Appellant respectfully requests that this Honorable Court address the issues presented and issue an Order
-requiring the Prothonotary to immediately Produce the COMPLETE record of the matter.
-requiring the immediate preparation and production of the transcripts for the matter.
-requiring the production of the missing exhibits referenced in transcripts.
which will permit this Appeal to proceed according to the schedule provided.

Respectfully Submitted,

/s/Terance Healy/s/
Terance Healy
Pro Se

c/o 871 Mustang Road
Warrington, PA 18976


IN THE SUPERIOR COURT OF PENNSYLVANIA

Sonya Healy	: Superior Court of Pennsylvania
(Appellee)	: 1330 EDA 2013
	:
v.	:
	:
Terance Healy	:
(Appellant)	:

PROOF OF SERVICE


I hereby certify that I am this 25th day of July, 2013 serving the foregoing

MOTION TO COMPEL PRODUCTION OF COMPLETE COURT RECORD

upon the persons and in the manner indicated below, which service satisfies the requirements of Pa. R.A.P. 121:

Service by FIRST CLASS MAIL	Sonya Healy
	c/o Angst & Angst
	Harleysville, PA

Service by FIRST CLASS MAIL	Mark Levy, Prothonotary
	Montgomery County Courthouse
	Norristown, PA

Service by FIRST CLASS MAIL	Judge Garrett Page
	Montgomery County Courthouse
	Norristown, PA

July 24, 2013
Terance Healy
Pro Se
c/o 871 Mustang Road
Warrington, PA 18976