Opinion
NO. 14 JD 15
06-06-2016
IN RE: ANGELES ROCA JUDGE OF THE COURT OF COMMON PLEAS FIRST JUDICIAL DISTRICT PHILADELPHIA COUNTY
Samuel C. Stretton, Esquire Attorney for Respondent, Angeles Roca 301 South High Street P.O. Box 3231 West Chester, PA 19381 (610) 696-4243 Attorney I.D. #18491
PRE-TRIAL MEMORANDUM OF JUDGE ANGELES ROCA
Judge Angeles Roca, by her counsel, Samuel C. Stretton, Esquire, hereby files her initial Pre-Trial Memorandum as follows.
I. List of Fact Witnesses
a.) Judge Angeles Roca
515 W. Girard Avenue
Philadelphia, PA 19123
Judge Roca will testify about the events in question.
b.) John Morris, Esquire
Kaufman, Coren & Ress, P.C.
2001 Market Street, Suite 3900
Philadelphia, PA 19103
Judge Morris was Judge Roca's prior attorney and will testify to certain statements made by individuals, and will provide a history of the case.
c.) Municipal Court Judge Bradley K. Moss
Criminal Justice Center, Room 1319
1301 Filbert Street
Philadelphia, PA 19107
Judge Moss is the Supervising Municipal Court Judge in Philadelphia and he will be called to testify as to the procedure for reopening, reargument and reconsideration in Municipal Court matters.
d.) President Judge Marsha Neifield
Criminal Justice Center, Room 1303
1301 Filbert Street
Philadelphia, PA 19107
Judge Neifield is the President Judge and the one who handled this case. She will testify that no one contacted to her.
e.) Ian Rexach
511 West Girard Avenue
Philadelphia, PA 19123
Mr. Rexach is the son of Judge Roca and may testify as to the circumstances of his matter.
f.) The Assistant City Solicitor who handled the tax case may be called, again to show the procedure and how the case was handled.
g.) Judge Roca reserves the right to call any witnesses referenced by the Judicial Conduct Board.
It must be noted that this case resolved itself for $447.00. This was not a criminal case, but a civil case.
Judge Roca reserves the right to call additional witnesses and reserves the right to supplement this Witness List.
II. Character Witnesses at Trial
During the trial, the following character witnesses may be called on the issue of Judge Roca's excellent character and excellent performance as a judge:
a.) Lee A. Schwartz, Esquire
1325 Spruce Street
Philadelphia, PA 19107
b.) Retired Judge Robert Matthews
8996 Pine Road
Philadelphia, PA 19115
c.) Walter J. McHugh, Esquire
McMonagle, Perri, McHugh & Mischak, P.C.
One Penn Square West
30 S. 15 St., Suite 701
Philadelphia, PA 19102
d.) Michael Fenerty, Esquire
Willig, Williams and Davidson
1845 Walnut Street
Philadelphia, PA 19103
e.) Ronald F. Abel, Esquire
1706 Race St
Ste 402
Philadelphia, PA 19103-1200
f.) Michael B. Grasso, Esquire
1706 Race St., Suite 406
Philadelphia, PA 19103-1200
g.) Joseph A. Guinan, Esquire
1706 Race Street, Suite 402
Philadelphia, PA 19103-1200
h.) Wendy Glazer, Esquire
2 Penn Center
Suite 10230
Philadelphia, PA 19102
i.) Mark Momjian
2005 Market Street
Suite 3510
Philadelphia, PA 19103
j.) Councilwoman Maria Quinones-Sanchez
City Hall, Room 330
Philadelphia, PA 19107-3290
k.) Oscar Rosado
858 N. Corinthan Street
Philadelphia, PA 19130
Mr. Rosado is the Chair of the Hispanic Affairs for the 6 ABC Community Advisory Board
l.) Retired Judge Nelson Diaz
Dilworth Paxon
1500 Market Street
Suite 3500
Philadelphia, PA 19102
m.) James Rocco, Esquire
1515 Market Street, #1801
Philadelphia, PA 19102
n.) State Representative Angel Cruz
3503 North B Street, Unit 7
Philadelphia, PA 19134
o.) Lisa Jordan, Esquire
1801 Market Street
Suite 1845
Philadelphia, PA 19103
p.) Iris Violeta Colon
760 S. Sheridan Street
Philadelphia, PA 19147
q.) Stephanie Gonzalez Fernandez, Esquire
501 E. Cambria Street
Bensalem, PA 192020
r.) Mary T. Vidas, Esquire
Blank Rome, LLP
One Logan Square
130 N. 18 Street
Philadelphia, PA 19103-6998
Judge Roca reserves the right to call additional witnesses and reserves the right to supplement this Witness List.
III. Proposed Trial Exhibits
a.) 2008 Tax Returns;
b.) Docket entries concerning the case at issue;
c.) Motion for Reconsideration;
d.) Trial exhibits listed by the Judicial Conduct Board
and all exhibits provided in discovery. Attached and marked as Exhibit "A" is the List of Exhibits provided by the Judicial Conduct Board and their letter dated February 16, 2016. All of these exhibits may be referenced or introduced.
e.) Tapes of all telephone conversations;
f.) All F.B.I. reports that have been provided.
IV. Stipulation
Present counsel is working on stipulations with the Judicial Conduct Board and there will be stipulations. There will be stipulations as to authenticity of all exhibits.
The Respondent, Judge Roca, through her counsel, Samuel C. Stretton, Esquire, certifies that all discovery and exhibits have been provided.
Respectfully submitted,
/s/_________
Samuel C. Stretton, Esquire
Attorney for Respondent,
Angeles Roca
301 South High Street
P.O. Box 3231
West Chester, PA 19381
(610) 696-4243
Attorney I.D. #18491
CERTIFICATE OF SERVICE
I hereby certify I am this date serving a copy of the Pre-Trial Memorandum of the Respondent, Judge Roca, in the captioned matter upon the following persons in the manner indicated below.
Service by First Class Mail addressed as follows:
1. Elizabeth A. Flaherty, Esquire
Deputy Counsel
Judicial Conduct Board
Pennsylvania Judicial Center
601 Commonwealth Ave., Suite 3500
P.O. Box 62525
Harrisburg, PA 17106
2. Honorable Angeles Roca
515 W. Girard Avenue
Philadelphia, PA 19123
Respectfully submitted, 6/3/16
Date
/s/_________
Samuel C. Stretton Esquire
Attorney for Respondent,
Angeles Roca
301 S. High St., P.O. Box 3231
West Chester, PA 19381-3231
(610) 696-4243
Attorney I.D. No. 18491