PLAINTIFF’S RESPONSE TO ATTORNEY GENERAL KANE’S MOTION TO DISMISS COMPLAINT

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	)

PLAINTIFF’S RESPONSE TO
ATTORNEY GENERAL KANE’S MOTION TO DISMISS COMPLAINT


1. Plaintiffs request that Attorney General Kane’s Motion to Dismiss pursuant to Rules 12(b)(1) and 12(b)(6) be DENIED with prejudice.

2. In the interest of continuing with the stated goal of a “just, speedy and inexpensive determination“ of this action, Plaintiffs request that the Motion to Dismiss be DENIED with prejudice so that the court will not be inundated with 55 further motions for dismissal raising these same standard procedural defenses by the Attorneys General, however DENIED without prejudice to raise the issue in their responsive pleadings to the challenge.

3. In support of this request, Plaintiffs present the attached Memorandum of Law.

NOT LAWFULLY ENACTED

4. Attorney General Kane has additionally indicated in her filings with the Court on this matter that the law being challenged was enacted by the Supreme Court of Pennsylvania and not enacted through the legislature, nor signed by a governor.

5. The Supreme Court of Pennsylvania through Rule 1.6 has given itself power over lawyers - which include the Governor, the Attorney General and a majority of the legislature - without due process.

6. All power to lawfully address the improperly enacted law has been removed from those responsible for lawmaking, the legislature and the Governor, and usurped by the Supreme Court of Pennsylvania. This is a clear violation of separation of powers.

7. Attorney General Kane has indicated a lack of jurisdiction, and having no ability to enforce the law being challenged. The power of enforcement unlawfully rests exclusively with the Supreme Court of Pennsylvania.

8. Rule 1.6 is authored, updated, edited, promoted, maintained, managed, directed and scripted by the American Bar Association. It is reasonable to question if the American Bar Association has effectively usurped the government of the Commonwealth of Pennsylvania, and each state where Rule 1.6 has been enacted.

9. Rule 1.6 denies litigants of the constitutionally protected right to petition the government for redress of grievances, denies a litigant of life, liberty and/or property without due process of law, and usurps the power of the government to address the issue by placing all power in one branch of government – the judiciary.

10. Rule 1.6 is unlawful and unconstitutional in every location where it has been enacted. Lawful action to challenge the law can only be done by those who are not required to follow it:
“Pro Se litigants with proper standing and a cause for relief - the restoration of rights and liberties protected by the U.S. Constitution.”

On behalf of the United States of America, Plaintiffs affirm their proper lawful standing to challenge the constitutionality of this improperly enacted law in every State, the District of Columbia and the US Virgin Islands.

Where Rule 1.6 has not been enacted into law, Attorneys General are on notice of this Constitutional Challenge and the impact the Rule can have on the civil rights and liberties of the People.

Respectfully,

Terance Healy	Todd M. Krautheim
c/o 871 Mustang Road	207 Woodspring Circle
Warrington, PA 18976	Doylestown, PA 18901