Motion for Reconsideration

Filed in Superior Court - PDF Version
IN THE SUPERIOR COURT OF PENNSYLVANIA
PHILADELPHIA, PENNSYLVANIA

Sonya Healy	:
(Appellee)	: # 1330 EDA 2013
	:
v.	:
	:
Terance Healy	:
(Appellant)	:

MOTION FOR RECONSIDERATION

In the unsigned MEMORANDUM filed October 27, 2014, NO EVIDENCE OF JURISDICTION for the lower court to issue the defective and void Order of May 9, 2011 is addressed, affirmed, available, asserted, authenticated, authorized, achieved, accomplished, attained, concluded, cited, confirmed, created, corroborated, discerned, determined, declared, earned, effectuated, enacted, endorsed, established, excused, filed, found, furnished, gained, granted, inherent, maintained, managed, offered, presented, provided, permitted, professed, pronounced, produced, ratified, substantiated, settled, served, supported, transmitted, unnecessary or waived.

Jurisdiction, when challenged, must be proven, not imagined.

The lack of jurisdiction for the lower Court to issue the defective and void Order of May 9, 2011 has erroneously been COMPLETELY IGNORED AND NEGLECTED by this Honorable and Superior Court.

Terance Healy (Appellant) has presented the evidence contained within the court record of the procedural defects which result in a lack of jurisdiction.

Sonya Healy (Appellee), represented by Angst & Angst, has at no time ever provided the court with evidence of proper jurisdiction and has ignored the challenge to the jurisdiction of the Court.

ANGST & ANGST have litigated by providing further issues and failures which exacerbate and demonstrate their complete disregard for procedure, process, and law; conducting ex parte communications with the court; then successfully leveraging their improper activities with the result affecting the integrity of the court. The chaotic disinformation tactics used by Angst & Angst to conceal their fraud upon the court since 2007, have been documented, demonstrated, evidenced and yet ignored by the entire Montgomery County Bench.


Where this Honorable court has added to the 'procedural quagmire' by failing to address the issue of jurisdiction,

Appellant demands the Superior Court to produce a true and correct statement of evidence proving all elements of jurisdiction for the Order of May 9, 2011 which completely and lawfully addresses the specific defects already documented by the Appellant and not citing collateral and irrelevant law which only serves to distract from the issue.

- or -

WHERE support of jurisdiction is lacking, is unavailable, does not exist, and/or has never been presented by any court, nor any Appellee, nor any attorney at ANGST & ANGST,

Appellant demands the Superior Court to strike the Order of May 9, 2011 as VOID AB INITIO;

and

Appellant demands the Superior Court to strike all subsequent orders issued which are affected by the defective and void Order of May 9, 2011 as VOID AB INITIO;

and

Appellant demands the Superior Court to immediately set aside the Memorandum of October 27, 2014;

and

Appellant respectfully requests twenty certified copies of those Orders for use in other pending matters where the defective and void order has been improperly and illegally presented and enforced.

Respectfully,

Terance Healy

FILED IN PERSON - OCTOBER 30, 2014.