Dawn Naret’, Attorney, Informa Pauperis
P.O. Box 643
Lancaster, Pa 17608-0643Commonwealth Court of Pa.
Office of the Prothonotary
Irvis Office Bldg. – Rm. 624
Harrisburg, Pa 17120
Regarding: Appellants 11/8/04 Motion to Remand or reverse with Prejudice and 11/10/04 Addendum to be appended to that Motion.
No. 1742 CD 2004
Dear Mr. Schuckers,
I was awaiting a response, from the UCBR office, within the required 20 days, to the Motion to Remand or Reverse with Prejudice, filed by me 11/8/04, (prior to the 11/12/04 dead-line for brief submission).
What I received is a partial response to only a few items of contention that prompted the Motion. I can only be liberal to the UCBR and assume that they have given a timely response to that Motion with their 11/24/04 communication, stated in the form of a request for Motion to Dismiss the Appeal of the Petitioner. (???)
It is an unusual response, considering the evidence presented in the Motion to Remand or Reverse with Prejudice/plus Addendum. I am very certain that a dismissal would be, without a doubt, a very serious violation of all laws, codes and procedures that they are obligated to comply with.
Their denial of Due Process was one of the contentious issues and the illegal denial of benefits, where willful misconduct was not proven or stated by the employer, relegate this case beyond the possibility of legal dismissal.
Therefore, I am submitting an OPPOSITION TO THE MOTION TO DISMISS PETITIONER’S APPEAL and also requesting that the justification of this opposition be summarized in my permissible REPLY TO THEIR RESPONSE, as I am submitting it within the required 10 days and I am willing, as I said, to be liberal as to the venue of their 11/24/04 communication.
I hold no negative opinions toward any of the staff currently focusing on this case. I am fully aware of the difficulties they have encountered with staff replacements and various other cogs in the wheel.
I consider myself fortunate that Mr. Gerard Mackarevich, Deputy Chief Counsel and Ms. Janet M. Tarczy, Assistant Counsel, should have been willing to come in on this problem situation at such a late date.
I have addressed the Certificate of Service to both or either Mr. Mackarevich or Ms. Tarczy, since I have not been told whom to consider the official replacement of Attorney Clifford Blaze, who left in August 2004.
There has been, repeated lack of communication as well as misinformation that created an unfair tragedy including now; eviction and homelessness, due to the illegal withholding of UC benefit funds.
Because of the situation advancing to such an intensely serious miscarriage of justice, I must beg your compassion and assistance in expediting the reversal and release of UC funds immediately. I have no phone either, and cannot continue to accomplish these necessary clerical communications and requirements.
It is not an incompetence on my part, it is an injustice that I should be required to suffer through so much difficulty to receive what I am already entitled to and was already approved for, before the referee erred in her judgment and knowledge of the UCBR laws.
Thank you and regards,
Current Contact Info as of 2-23-07:
P.O. Box 2315 Pittsburgh, Pa 15230-2315
Old Original Contact Info: see below
P.O. Box 643
Lancaster, Pa 17608Email: reply2dn@Gmail.com
Msg. Svc.: 717-481-2980