Showing posts with label EXHIBIT. Show all posts
Showing posts with label EXHIBIT. Show all posts

Friday, October 18, 2013

REQUEST FOR ADMISSIONS UNDER RULE 36

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)


REQUEST FOR ADMISSIONS UNDER RULE 36


The plaintiffs ask the Attorneys General to respond within 30 days to these requests by admitting, for purposes of this action only and subject to objections to admissibility at trial:

1. The genuineness of the following documents, copies of which are attached.

a) Montgomery County Court of Common Pleas, Norristown, PA Docket# 2007-12477
b) The Superior Court of Pennsylvania, Philadelphia, PA Docket# 1330 EDA 2013
c) The Supreme Court of Pennsylvania, Harrisburg, PA Docket# 155 MM 2013
d) Montgomery County Court of Common Pleas, Norristown PA Docket# 2013-29976
e) Bucks County Court of Common Pleas, Doylestown, PA Docket# 2011-00193
f) Bucks County Court of Common Pleas, Doylestown, PA Docket# 2012-05546
g) Bucks County Court of Common Pleas, Doylestown, PA Docket# 2013-07214






Terance HealyTodd M. Krautheim
c/o 871 Mustang Road207 Woodspring Circle
Warrington, PA 18976Doylestown, PA 18901


EXHIBIT A
Montgomery County Court of Common Pleas
Norristown, PA
Docket# 2007-12477

EXHIBIT B
The Superior Court of Pennsylvania
Philadelphia, PA
Docket# 1330 EDA 2013

EXHIBIT C
The Supreme Court of Pennsylvania
Harrisburg, PA
Docket# 155 MM 2013

EXHIBIT D
Montgomery County Court of Common Pleas
Norristown PA
Docket# 2013-29976

EXHIBIT E
Bucks County Court of Common Pleas
Doylestown, PA
Docket# 2011-00193

EXHIBIT F
Bucks County Court of Common Pleas
Doylestown, PA
Docket# 2012-05546

EXHIBIT G
Bucks County Court of Common Pleas
Doylestown, PA
Docket# 2013-07214

Friday, July 12, 2013

To the Court Reporters:

Message to the Court Reporters:

Please advise the court reporters that I plan to file a complaint with the Superior Court regarding their deliberate failure to produce the transcripts as required by the Rules of Appellate Procedure.

I will additionally be filing federal suits against each for their participation in the obstruction of justice and denial of due process which they have chosen to become involved in.

Judge Page lacked jurisdiction and engaged in intimidation tactics to prevent justice in this matter.

Please advise your reporters accordingly.
Terance Healy
www.work2bdone.com/live



Email Exchange Regarding Court Reporter Preparation of Transcripts.

1. On April 30, 2013, upon receipt of the Order Granting Permission to Proceed In Forma Pauperis, Appellant/Defendant filed the document with the Prothonotary.
( #2007-12477-391 ) ( EXHIBIT A )

2. Appellant/Defendant then went to the Court Reporters Office to arrange for the production of the transcripts for the matter. Appellant/Defendant met with P. Fajardo, and also met briefly with Byron Battle, Chief Court Reporter..

3. Appellant/Defendant was traveling to Florida the next morning to attend the funeral of his father who had passed away on April 28, 2013. ( EXHIBIT B )

4. During his time in Florida, Appellant/Defendant contacted P. Fajardo by telephone to update the list of transcripts necessary for the Appeal.

5. On May 15, 2013, upon his return, Appellant/Defendant filed with the Prothonotary a Notice “Request for the Production of Transcripts” listing the transcripts necessary for the Appeal. ( #2007-12477-394 ) The Notice included a signed copy of the Order Granting Permission to Proceed In Forma Pauperis.

6. On May 15, 2013, a copy of the time-stamped Notice “Request for the Production of Transcripts” was emailed to P. Fajardo in the Court Reporters Office. ( EXHIBIT C )

7. On May 15, 2013, P. Fajardo acknowledged receipt of the listing, and accepted responsibility to notify the appropriate Court Reporters. ( EXHIBIT D )

8. On May 16, 2013, the Court Reporters' Office was thanked by the Appellant/Defendant, and exhibits missing from the official transcript for February 11 & 20, 2013 were raised as a concern. (EXHIBIT E )

9. On May 16, 2013, P. Fajardo indicated that the Appellant/Defendant would be contacted if any further information was required. ( EXHIBIT F )

10. On May 19, 2013, the Court Reporters' Office was thanked by the Appellant/Defendant who inquired as to when the transcripts would be available to review. ( EXHIBIT G )

11. On May 20, 2013, P. Fajardo indicated that my inquiry would be forwarded to the individual court reporters. ( EXHIBIT H )

12. On May 20, 2013, Appellant/Defendant was contacted by Byron Battle, Chief Court Reporter, by telephone. Byron indicated that Judge Page had contacted the court reporters with instructions to NOT prepare the transcripts.

13. On May 21, 2013, Appellant/Defendant wrote to the Court Reporters Office requesting that they continue to work towards producing the hearing transcripts, as there had been no information shared by Judge Page; no contact between Judge Page and the Appellant/Defendant; no hearing or conference had been petitioned; no hearing or conference had been scheduled; no hearing or conference had been held. ( EXHIBIT I )


14. On May, 21, 2013, Appellant /Defendant received via email the transcript for a brief proceeding held on January 17, 2013. The Court Reporter additionally filed a copy of the transcript with the Prothonotary. ( #2007-12477-397 ) ( EXHIBIT J )

15. On May 22, 2013, Appellant/Defendant emailed P. Fajardo requesting the name of who had added the transcript for the brief proceeding on January 17, 2013 to the list of transcripts to be produced. ( EXHIBIT K )

16. On May 22, 2013, Appellant/Defendant resubmitted the Notice “Request for the Production of Transcripts” to clarify the transcripts required and the associated Court Reporter for each hearing. ( #2007-12477-398 ) ( EXHIBIT L )

17. On May 22, 2013, P. Fajardo responded to my email with a courtesy copy of a Court Order signed by Judge Garrett D. Page on May 21, 2013. ( EXHIBIT M )

18. On May 22, 2013, Appellant/Defendant acknowledged the email and the order, further calling attention to the courts lack of jurisdiction. The lack of jurisdiction was further compounded by the pendancy of a prior appeal which had been deliberately neglected by the Prothonotary. The Prothonotary failed to prepare and forward the matter to the Superior Court after the August 15, 2011 Notice of Appeal. The email additionally pointed out the overall injustice and corruption which has interfered with every aspect of the matter since 2007. ( EXHIBIT N )

19. On May 22, 2013, Appellant/Defendant assembled and posted the issues regarding the Order of May 21, 2013 to his web site, and opened up discussions with friends about how to address the issues. ( EXHIBIT O ) ( www.work2bdone.com/live )

20. On May 22, 2013, Appellant/Defendant emailed the Court Reporter who had transcribed the January 17, 2013 requesting the name of the person who requested/authorized the transcription of the matter. ( EXHIBIT P )

21. On May 23, 2013, the Order of May 21, 2013 signed by Judge Garrett D. Page was filed and docketed with the Prothonotary. ( #2007-12477-399 ) ( EXHIBIT Q )

22. On May 23, 2013, the Court Reporter indicated via email that Byron Battle, Chief Court Reporter, had instructed her to transcribe the proceeding from January 17, 2013, and that she believed that it was at the request of Judge Page. ( EXHIBIT R )

23. On May 23, 2013, the Court Reporter followed up her email with another indicating that as a result of the Judge's recent Order, I would be expected to make arrangements for payment for the transcripts prior to them being transcribed and produced for the Superior Court.
( EXHIBIT S )

24. On May 24, 2013, Appellant/Defendant emailed the Court Reporter to clarify the issues involved. In a follow up email, Appellant/Defendant further indicated that Judge Page lacked jurisdiction to revoke his Order Granting Permission to Proceed In Forma Pauperis, and it appeared as if Judge Page was attempting to prevent the record from being delivered to the Superior Court. ( EXHIBIT T )
COURT REPORTERS HAVE EACH INDIVIDUALLY CORRESPONDED DIRECTLY INDICATING THEIR REFUSAL TO PRODUCE THE TRANSCRIPTS.