ADDENDUM - PLAINTIFFS QUESTIONS / ISSUES

ADDENDUM - PLAINTIFFS QUESTIONS / ISSUES

The Pennsylvania Attorney General Neglects to Address the Questions /Issues presented in the Plaintiffs' Appellate Brief.

Question #1
Did the Court fail to act pursuant to FRCP 5.1(b) CERTIFICATION BY THE COURT of a Constitutional Challenge?

CERTIFICATION BY THE COURT would have had the Court query each Attorney General or state Supreme Court requesting their position on the question.

IS RULE 1.6 CONSTITUTIONAL?
DOES RULE 1.6 CAUSE A DENIAL OF CONSTITUTIONALLY PROTECT RIGHTS OF LITIGANTS.

The Pennsylvania Attorney General does not indicate the position that the law being challenged is constitutional.

Question #2
Did the Court fail to act pursuant to Rule 5.1(c) INTERVENTION of a Constitutional Challenge?

A summons and complaint was NOT served upon United States Attorney General, Eric Holder, by the court advising of the constitutional question being challenged in the Court.

Only after filing of the Notice of Appeal did the Court serve a copy of the constitutional complaint upon the United States Attorney General on December 5, 2013.

Question #3
Did the Court ignore, deny, prevent and obstruct the Attorneys General from intentional default in the matter?

Any effort to involve the fifty-five non-Pennsylvania Attorneys General, who were properly served the constitutional matter by the Plaintiffs, was prevented by the Court.

Any effort to determine if the Attorneys General intended to default on the matter was prevented by the Court.

The Pennsylvania Attorney General fails to explain how fifty-five (55) Attorneys General who were NOT served with the Motion for Extension of the Responsive Pleading Deadline where “Attorney General Kane does not represent the other defendants.” all failed to file any answer to the summons and constitutional challenge by their “answer due” date.

Question #4
Did the court incorrectly dismiss the matter without basis in law while failing to substantiate any justification for dismissal in law, doctrine or case law?

This question is addressed in the misinformation of the Appellee Brief with information clarified and corrected in this document.

Question #5
Did the Court fail to reconsider the matter based on an incorrect application of LRCP Rule 7.1(g) where Rule FRCP Rule 52(b) applies to an action which concludes the matter before the court?

In a multi-page prolonged footnote, the Pennsylvania Attorney General engages in a speculative and circular argument which fails to indicate or explain why there was no response to the Plaintiffs' Motion for Reconsideration.

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In the Third Circuit Court of Appeals #13-4591

Notice of Appeal (PDF)

Civil Appeal Information Statement (PDF)

Concise Summary of the Case (PDF)

Certificate of Service (PDF)

THE CASE

Terance Healy and Todd M. Krautheim have filed a Constitutional Challenge with the Attorneys General of the United States regarding Rule 1.6 Confidentiality of Information of the Rules of Professional Conduct as the rule causes the complete denial of constitutionally protected rights while subverting justice and corrupting the integrity of the judiciary.

Healy and Krautheim seek a determination that the state law is unconstitutional which will restore their rights in the state, and restore the integrity of the judiciary and the reputation of professionals involved in the process and enforcement of law.

A finding of 'unconstitutional' will permit the state to address litigants with their civil rights in full force and effect without a 'lawful' mandate which denies law, obstructs justice and negatively affects the integrity of the courts.

Their cases in the state courts are presented as evidence of the denial of rights. Healy and Krautheim do not seek this courts direct involvment or action regarding decisions in those matters.

Healy and Krautheim act 'in the name of the United States' to challenge the same law in place in every state.


STATEMENT

The Court neglected CERTIFICATION BY THE COURT of the Constitutional Challenge pursuant to Rule 5.1(b).

The Court neglected INTERVENTION of the Constitutional Challenge pursuant to Rule 5.1(c).

The Court neglected to update the docket upon proof of service to all Attorneys General by the Plaintiffs.

The Court failed to acknowledge any intentional default by the Attorneys General, or to permit any indication of that intent.

The Court delayed ruling on Plaintiff's ECF filing request for over 6 weeks.

The Court neglected to address errors and misrepresentations on the docket when presented.

The Court memorandum did not support or substantiate any element for dismissal, yet was provided to justify the illogical conclusion to dismiss the complaint and the improper finding of futility.

The Court further denied reconsideration of the dismissal of the matter by referencing the wrong rule.


QUESTIONS ON APPEAL

Did the Court fail to act pursuant to FRCP Rule 5.1(b) CERTIFICATION BY THE COURT of a Constitutional Challenge?

Did the Court fail to act pursuant to Rule 5.1(c) INTERVENTION of a Constitutional Challenge?

Did the Court ignore, deny, prevent and obstruct the Attorneys General from intentional default in the matter?

Did the Court incorrectly dismiss the matter without basis in law while failing to substantiate any justification for dismissal in law, doctrine or caselaw?

Did the Court fail to reconsider the matter based on an incorrect application of FRCP 7.1(g) where FRCP Rule 52(b) applies to an action which concludes the matter before the court?

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The Caption for the Appeal

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT
PHILADELPHIA, PENNSYLVANIA

Terance Healy	:
Todd M. Krautheim	:
In the name of THE UNITED STATES	: Case Number: 13-4591
	:
v.	:
	:
Kathleen Kane	:
Pennsylvania Attorney General;	:
And	:
The Attorneys General of the United States	:
	:
v.	:
	:
Eric Holder	:
United States Attorney General	:
	: