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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~. PENNA.
KAREN CRAIG,
Plaintiff
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96-1666
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ROBERT CRAIG, II,
Defendant
DECREE IN
DIVORCE
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KAREN CRAIG
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are divorced from the bonds of matrimony,
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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The Marriage Settlement Agreement and Stipulation are
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KAREN J. CRAIG,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
:
: NO. 'J(, /I.UCML TERM
ROBERT E. CRAIG, II, : IN DIVORCE
Defendant :
OHDER OF COUHT
AND NOW, Ihh_ H dny of~, 1996, upon cOlIsidernlion of Ihe IIl\llched
COlllplllilll, il is hereby direcled Ihut the pnrli,'s II III I their respective counsel IIppellr before
D (,-,-V '\ S ),^",I" I ,the COllciliator, ut 51;[ Lv /V, c,', n S; 't fVl<!-(L1"",. ,b,,'.:>
,
, Oil the 7j J, duy of /'v).,t
, 1996, ul JC~O o'clock .a,m" for u Pre-Heuring Custody Conference, AI such
conference, un efforl will be mude to resolve the issu,'s in dispute; or if Ihis cannol be
uccomplished, 10 define ulld lIurrow the iSSUl'S to be h,'unl by the Courl, and to enter inlo II
lemporary order, Failure 10 appear al Ihe conference may providc grounds for enlry of 8
lemporary or penllunenl order,
FOR THE COURT,
By: ~, u-rj ,!L,Jd ':;':'1,
Custody Conciliator t:/ ~~ /
YOUR SHOULD TAKE THIS PAPEH TO YOUI{ LAWYER AT ONCE, "" YOU DO NOT
HAVE A LAWYER OR CANNOT AFFOHO ONE, GO TO OH TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WII~:HE YOU CAN GET LEGAL IIELP,
OFFICE or TflE COURT ADMINISTHATOH
CUMBEHLAND COUNTY COlJHTlIOUS~:
CAHLlSLE, PA 1701:~
(717) 240-6200
8, The murriuge lH'twel'n the pllrtle~ hNl'to i~ irretrieyubly broken,
9. Pluintlff rel(ue~l~ the Court to .'nlt'r u .I,.er.... of .liyon:.:,
COUNT II . CHILD CUSTODY
10. Pluintiff incorp()rnte~ Ill'n~in th., prior pllrngruph~ by n'fer.'nce,
11. Pluintiff seeks leglll uml phy~icul clI~ttKly of th.. purti..s' two minor children,
Zachary Robert Craig, age 3, date of birth 12/5/92, und Leo Anthony Cruig, uge I, date of
birth 3/15/95, who currently reside since Junu/lry 1996, with tbeir mother, Karen J, Craig,
In Mechanicsburg, Cumberlund County, P,'nnsylvuniu 17055,
12, The children wert' not bom out of we.llock,
13, The children are presently in the custody of their mother, the Plaintiff,
14, From birth, the children huy,' resided with the following pel'llons and at the
following addresses:
From birth until February 1993, at 155 State Road, Mechanicsburg, Cumberland
County, Pennsylvania, with the Plaintiff and Defendunt,
From February, 1993 to June 1993, in 5t, Jo~"ph, Jeffel'llon County, Missouri, with the
Plaintiff :lIld Defendant,
During early June 199~l, in Okluhomll City, Okluholllll, with the Plaintiff and
Defendant,
From mid June, 199~ to August 1993, in Ub,'rul, Kllnsus, with the Plaintiff and
D,'fendanl.
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rrom AlIglI~1 199:1, 10 IJ.'e.'mllt'r 1994, III 10 Killillg.'r ROIllI, Eth....... P.'III1~ylvllllill,
with tIll' PIIIIIII!fr IIl1d D,'f.,/IIIIIIII.
rwm [).'ccmh"I' 199,t to jUllllllry I ()96, ul II SOlllh Bullllllorc Strc.'I, rrullklinlowlI,
Pellll~ylvlllliu, with hl~ hruther, 1..'0 AnlhollY Cruig, born Murch IS, 1995, ulong with lh..
Pluillliff IIl1d D.-fell.lunl,
rwm jllllllllry 1996. 10 pn'~.'nl, III 4:l11 Lind.'n Slr.'.'l, M"ehullic~hnrg, Cumherlulld
County, Pellll~ylvllnlu, wilh hi~ brolher, Leo Anthony CrniK, hi~ 1II0Ih.'r. llw Plllinllff, IIIILI hl~
mlllernul grnndplln'nl~,
15, Tlw 1II0thl'r of Ih.' child i~ Ihe Plllillliff, KAREN j, CRAIG, SIll' i~ lIIurried to
tlw Defendallt. ROBERT E, CRAIG, II, lint! reKide~ wilh th., purlie~ Iwo minor childrt'lI, IIlld
h..r pllrenf~.
16, Th.. futhel' of Ih.. child i~ Ihe DefelldulIl, IWBERT E, CRAIG, II, HI' i~ married
to the Pluintiff, KAREN j, CRAIG, ulld doe~ 1101 n'~id.. with Pluinliff or Ihe lwo lIIinor
childrell,
17, Plaillliff hus 1I0t parlieipuh't! liS u purly or wiln.'ss, or ill ullother cllpllcily, ill
other liligulioll cOllc.,rning Ih., custody of Ihe ehildrt'n in Ihis or unoth.'r Court,
18, Olher thun us ~llIled uhov." Pluinliff hus no infol'lIIulion of u eU~I(}(ly proceedillg
concerning the ehildren p.'ndinK in u COlll't of llIis COIIIIllOIIW.'ulth,
19. Plailltiff does 1101 know of uny otlll'r p.'rson or party 10 llll' proeeedillgs who has
phy~icul clIstody of th., ehildr"1I 01' e!llims 10 hav.' ellslody or visitutioll right~ with respecl
10 th.. childrell,
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20, Thl:' I)('~I IlIlt'rl:'~t~ nlld Pl'n1Ullll'lIt wdfun' of Ihe l:hildrell will he ~ervl:'d by
grulltlllg Ihe rl'lil'f re'llll'~lt'd Ill'enll~l' Ihl' PIlIlllllff i~ n lovillg pun'lIl uhle to cnre for Ihe
childrell ullll CII~IUlly will ufford Ih,' dlildn'lI Ihl' 1I11IKIIlIIIIlI ~Iuhillty ill thdr hOllle
ellVirOIlIlll'III,
21. Ench purellt Wll<)~l' pun'lItul ri~lll~ to I Ill' dlildn'lI hnve 1I0t h""lItcnnillllted ulld
thc pel'llOIl whollll~ phy~Icul ell~lody of tIll' dlildrell hu~ h",'nlHlIIl,'d u~ u purly lolhi>luclion.
22, There nr,' 110 other per~on~ who nre known 10 hnv,' or c1uim n rlghllo cU~lody
or vi~llulioll rlght~ of th,' children.
COUNT III . ALIMONY AND ALIMONY PENDENTE LITE
2a, Plnllltiff illcorpornll's h,'n'ill Ih,' prior purllgruph~ hy reference,
24, During the ('l)lJr~" of her IlIl11'rillg", Ihe I'luillliff hns heen fillnllcilllly dependent
IIpon Ihe Dl'f'endunl.
25, The Pluillliff i~ pres"nlly IIl1llbll'Io work d'H' to cOlllpliclllioll8 of her pregnullcy.
IInd i8 IIl1l1hle to 811pport her~df ill Ihe life8lyl,' to which she wns IIccu>llonll'd to during Ihe
llIurrillge of Ihe parties,
26, The Def,'ndallt is fillnncinlly nble to n8si81 his wife with the fel:'>I, cosl>l and
"XIll'ns,'s of Ihis aClion nnd wilh Ih,' expl'lISC of rcusollahle cOllnsd f,'l:'s. The Plllintiff is in
lIeed of IIlilllllllY p'~rlllelltl' lile to IIIlIilllnill hl'rself durillg Ihe cOllrse of Ihi~ action and to
p,'rnumelll alilllony Ihen'afl,'r if sIll' is 10 IlIl1intnin her lifestyle.
4
COUNT IV . COUNSEL FEES, COSTS AND EXPENSES
27, Pluinliff incorporntl's hl'rein lhl' prior pnrugruphs hy n'fl'n'nce,
28, Pluinliff is nol ill u l'inulldul f)C/sitioll 10 1II1'l't tIll' 1:081s ulld expen8e8 of
prOllcculing Ihis Ulllioll or 10 puy n'u8ollllhll' coullsl,l fel's to 111'1' ullol'lley,
29, The DefendulIl is l'illullciully uhll' 10 suppol'l his wife ulld based 011 pusl wages
hus un eUnlillg llUpucily ill l'xcess of $:15,000 or 11I01'1' per yeur, us u millwright.
COUNT V . EQUITABLE DISTRIBUTION
30. Pluinliff IlIcorporutl'S Ill'reiu till' prior purngrnphs by I'eferellce.
31, The purlieSlll'l' the oWlle"" of pl'rSll/lul property subjl'ctlo equituble distribution
between them liS lIIuritlll property,
32. The Pluilltlff n'qul'sts Ihe Court to l'quitubly divide such itelll8 of IIIl1rital
property betweell tl1l'm,
WHEltEF'ORE, the Pluillliff requests this Court 10:
a. Enler a filial Decree of Divorce divorcillg the Plaintiff 1'1'011I the
Defelldant;
b, Awurd tl1l' purties shlln'd Il'F;lIl custOlly Ulld nwnrd the Plllillliff primary
physical custody of the Pllrtles' millOI' children subject to reasonable
visitulion with the Defendllllt;
c, Awurd Plllillllff rl'IIS01l1lbll' I:OUIISl'! fees, expellses IIl1d cOSt8 of suit in
this molter;
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KAREN J. CRAIG,
Plaintiff,
: COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
,
: DOCKET NO, 96-1666
ROBERT E. CRAIG, II,
Defendant,
AFFIDAVIT OF CONSEN1'
yg
WAIVER OF NQTJCE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECllEE
UNDER II 330He) OF TIIF; DIVORCE CODE
1, A complaint in divorce under Section 3301(c) of the Divorce Code was
med on March 28, 1996 and served on April 4, 1996,
2, The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of the Complaint,
3, I consent to the entry of a final decree of divorce without service of notice
of intention to request entry of the decree,
4. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted,
5, I understand that I will not be divorced I'ntil a divorce decree is entered by
the Court and that a copy of the decree wilI be Bent to me immediately after it is filed
with the prothonotary,
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
~ 4904 relating to unsworn falsification to authorities,
Date: ;;ht}s
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.44/'~ C'<h'.-~
ROBERT E, crfAIo, II
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ROBERT CRAIG,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 96-1666
IN DIVORCE
v.
KAREN CRAIG,
Defendant
ORDER APPOINTING MASTER ,._,
...(- J. ' A) , ( l'l /lr~/'\
AND NOW):) day ofee ""/1996/ Ie Ii- l- , Is appointed master with
respect to the folfowing claims: ()
(1) Divorce
(2) Distribution of property.
BY T E COURT:
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KAREN CRAIG,
Plaintiff
. : IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
ROBERT CRAIG, II
Defendant
: NO, 96-1666
: IN DIVORCE
INCOME AND EXPENSE STATEMENT
OF
ROBERT CRAIG, II
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The undersigned files the following Income and Expense Statement.
I understand that false statements herein are made subject to the penalties of 18 Pa,
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C,S. ~4904, relating to unsworn falsification to authorities,
Date: ~v.......I... J~ 1"~1
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Robert Craig, II
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EXPENSES:
Week Month Year
(Fill in Appropriate Column)
Home
Mortgage/rent $ $ 100,00 $
Maintenance
Utilities
Electric 70.00
Gas
Oil
Telephone 100,00
Water
Sewer
Employment
Public trans. $ $ $
Lunch 20,00
Taxes
Real estate $ $ $
persl, property (land)
Income (Personal)
Insurance
Homeowners $ $ $
Automobile
Life
Accident
Health
Other (Cancer Ins, )
Automobile
Payments $ $ $
Fuel
Repairs
Medical
Doctor $ $ $
Dentist
Orthodontist
Hospital (Lab)
Medicine -
Special needs
(glasses, braces I
ortho, devices)
Education
Private school $ $ $
Parochial school
College ( I CS course)
Religious
Personal
Clothing $ $ $
Food 200,00
Barber/hairdresser 15.00
Credit payments
Charge account
Memberships
1"""\
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EXPENSES CONTINUED:
Loans
Credit Union
Week Month Year
(Fill in Appropriate Column)
$
$
$
Miscellaneous
Houaehold help $ $ $
Child care
Papers/books/mag,
Entertainment
Pay TV $ $ $
Vacation
Gifts
Legal fees
Charitable contrib,
Other child support
Alimony payments 223,00
Other $ $ $
TOTAL EXPENSES: $
$ 535.00
$
PROPERTY OWNED
Checking Accts,
Savings Accts,
Credit Union
Stocks/bonds
Description
PNC
Value
$ ~,OO
OWNERSHIp.
H W J
X
Real estate
Other
IRA
TOTAL:
$
$
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ASSETS OF PARTIES
Defendant, ROBERT CRAIG, II, marks on the list below those Items applicable to the
() 1.
(X) 2,
() 3,
( ) 4.
(X) 5,
( ) 6,
( ) 7,
( ) 8,
( ) 9,
() 10,
( ) 11.
( ) 12,
( ) 13.
(X) 14,
( ) 15,
() 16,
(X) 17,
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( ) 20.
( ) 21.
( ) 22,
() 23,
() 24,
(X) 25,
( ) 26.
case at bar and Itemizes the assets on the following pages,
Real property
Motor vehicles
Stock, bonds, securities and options
Certificates of deposit
Checking accounts, cash
Savings accounts, money market and savings certificates
Contents of safe deposit boxes
Trusts
life Insurance policies (indicate face value, cash surrender value and current
beneficiaries)
Annuities
Gifts
Inheritances
Patents, copyrights, inventions, royalties
Personal property outside the home
Businesses (list all owners, including percentage of ownership, and
officer/director positions held by a party with company)
Employment termination benefits - severance pay, workman's compensation
claim/award
Profit sharing plans
Pension plans (indicate employee contribution and date plan vests)
Retirement plans, individual retirement accounts
Disability payments
litigation claims (matured and unmatured)
MilitaryNA benefits
Education benefits
Debts due, including loans, mortgages held
Household furnishings and personalty (include as a total category and attach
itemized list if distribution of such assets is in dispute
Other
1""'\
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LIABILITIES
Item
Number
Description of Property
Names of All
Creditors
Names of All
Debtors
KAREN J. CRAIG,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 1666 CIVIL
vs.
ROBERT E. CRAIG, II,
Defendant
IN DIVORCE
THE MASTER: Today is Tuesday, July 21, 1998. This
is the date set for a Master's hearing in the above captioned
divorce case.
Present in the hearing room are the Plaintiff,
Karen J. Craig, and her counsel Andrea C. Jacobsen, and the
Defendant, Robert E. Craig, II, and his counsel Austin F.
Grogan.
A divorce complaint was filed on March 28, 1996,
raising grounds for divorce of irretrievable breakdown of the
marriage. The parties have indicated that they are going to
sign affidavits of consent and waivers of notice of intention to
request entry of divorce decree so that the divorce can be
concluded under Section 3301(c) of the Domestic Relations Code.
Counsel will provide the Master with the affidavits and waivers
and the Master will file those documents with the Prothonotary.
The divorce complaint also raised the economic
claims of alimony, alimony pendente lite, equitable
distribution, and counsel fees and expenses.
The parties were married on October 9, 1992, and
separated January 10, 1996. There are three minor children of
thi. marriage.
The Master has been advised that after negotiaeions
this morning the parties and counsel have reached an agreement
with respect to the outstanding economic claima. The agreement
is going to be placed on the record in the presence of the
parties. The agreement as stated on the record will be
considered the substantive agreement of the part:,es not subject
to any changes or modifications except for correction of
typographical errors which may be made during the transcription.
The parties will return later this morning to
review the agreement for typographical errors and make any
corrections as required and then affix their signatures by way
of affirmation of the terms of the agreement. It is understood
specifically that no substantive changes can be made to the
agreement when the parties return or at any time in the future.
After the Master has been provided with a signed
document, the Master will prepare an order vacating his
appointment and counsel can file a praecipe to transmit the
record to the Court requesting a final decree in divorce. Mr.
Grogan.
MR. GROGAN: Thank you.
1. The parties have agreed to withdraw the economic claim
for equitable distribution as well as the claims for
counsel fees and costs and alimony pendente lite.
2. As the agreement relates to the count for alimony, the
parties agree that the Defendant, Robert E. Craig, II,
.,1
will pay the Plaintiff, Karen J. Craig, $50.00 per week
for a period of two years. In the event of remarriage or
cohabitation of wife the alimony will terminate. The
alimony will also terminate upon the death of either
party.
During the period of alimony, the Defendant, Robert E.
Craig, II, will be entitled to the tax deduction benefit
of two of the three minor children of the marriage and
wife will sign the necessary forms with the Internal
Revenue Service to allow husband to take the necessary
deduction for federal income tax purposes.
The agreed alimony payment of $50.00 per week is
nonmodifiable other than for the reasons previously set
forth in the termination section.
3. Robert E. Craig, II, agrees to pay Karen J. Craig a total
of $137.60 for past medical reimbursements that were
received by Robert E. Craig, II, and cashed by him which
were due to Karen J. Craig.
4. There is no further agreement between the parties as to
their respective claims for reimbursement of medical
expenses which mayor may not be payable under the
terms of a support order entered through the Domestic
Relations section of York County, Court of Common Pleas.
5. Robert E. craig, II, will not cut the children's hair
without prior approval of the mother Karen J. Craig.
,
6. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each party
hereby waives and relinquishes any and all rights he or
she may now have or hereafter acquire under the present
or future laws of any juriSdiction to share in the
property or the estate of the other as a result of the
marital relationship including without limitation,
statutory allowance, widow's allowance, right of
intestacy, right to take against the will of the other,
and right to act a~ administrator or executor in the
other's estate. Each will at the request of the other
execute, acknowledge, and deliver any and all instrument.
which may be necessary or advisable to carry into effect
this mutual waiver and relinquishment of all such
interests, rights, and claims.
7. Notwithstanding the foregoing, the parties agr.e that
husband shall continue to pay wife's spousal support
, ,
you've agreed that this alimony payment is only tor a detinite
period of time and would terminate at the end ot two years, it
not sooner?
MS. CRAIG: Yes.
MS. JACOBSEN: And that's agreeable to you?
MS. CRAIG:
MR. GROGAN:
MR. CRAIG:
MR. GROGAN:
ot this agreement?
MR. CRAIG:
MR. GROGAN:
dictating?
MR. CRAIG:
MR. GROGAN:
dictated?
MR. CRAIG: No.
Yes.
State your name for the record?
Robert E. Craig, II.
Were you present during the dictation
Yes.
Did you understand what I was
Yes.
Do you have any questions about what I
agreement?
MR. GROGAN: Do you agree to the terms of the
MR. CRAIG: Yes.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms ot
settlement as set forth herein, and that by signing below I
ratify and atfirm the agreement previously made and intend to
bind myself to the settlement as a contract obligating myselt to
the terms of settlement and subjecting myself to the methods and
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KAREN ), CRAIG,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-1666
IN DIVORCE
Plaintiff
v.
ROBERT E, CRAIG, II,
Defendant
ORDER OF COURT
AND NOW, this \:5 day of St.'p't'r'l\bt' r 1997/ upon consideration of the
attached Petition to Modlfy, it is hereby directed that the parties and their respective counsel'
appear before .!'P.\,J....... s.... -S....nr\rl\. ~ the Conciliator, at ~ \,JAS. -\- _
\-"0\("\ ~\-" N~('h:r\\(S,'D-.r~)pA ,onthe \4 day of [:;c.\Ober .
1997/ .It \ \, () 0 o'clock -CL,m" for a Pre-Hearing Custody Conference, At such
conference, an effort will be made to resolve the issues in dispute; or if this cannot be
accomplished, to define and narrow the issues to be heard by the Court, and to enter into
a temporary order, Failure to appear atlhe conference may provide grounds for entry of a
temporary or permanent order,
BY THE COURT,
~)
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
OFFICE OF THE COURT ADMINISTRATOR
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
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C. HlIDorial Day, July 4th, Labor Day - The parties shaH make
arrangements by mutual agreement to share or alternate
custody of the Children on Memorial Day, July 4th, and
Labor Day.
5. Each party shall be entitled to have custody of the Children
for two nonconsecutive weeks during each sumner vacation lIpon providing
sixty (60) days notice to the other party. The party providing notice first
shall have preference for his or her chosen vacation days.
6. The parties shall cooperate in making t.ransportation
arrangements for exchanges of custody. When transportation is the
responsibility of the Father, transportation may be provided on his behalf
only by the Father's parents or the Father's sister. The parties shall
insure that the Children are transported in appropriate car seats,
7. In the event the ~'ather is unavailable due to his employment
or otherwise during his weekend periods of partial custody, the Father shall
make arrangements for the Childr3n's care with the Mother, the Father's
parents or the Father's sister.
8. If either party intends to remove the Children from his or her
residence for an overnight periOd, that party shall provide the other party
with an address and telephone number where the Children can be contacted.
9. This Order is entered pursuant to an agreement of the paL"ties
at a Custody Conciliation Conference. The parties may modify the provisions
of this Order by mutual consent. In the absence of mutual consent, the
terms of this Order shall control.
BY THE COURT,
_~ ce:
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Andrea C. Jacobeen, Esquire
Austin F. Grogan, Esquire
,/JJ-
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"
'I"
KAREN J. CRAIG, . IN THE COURT OF CCl'lMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
VS. NO. 96-1666 CIVIL TERM
ROBERT E. CRAIG, II, :
Defendant . IN CUSTODY
.
amooY <XIICILIATICIt ~ R.BI'(Rl'
IN ACa:IlDANC8 WI'1'II C1IIBI!RLAND CXUIrY RULB or CIVIL PAC..... ..-
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The relevant information pertaining to the Children who are the
subjects of this litigation is as follows:
~
Zachary Robert Craig
Leo Anthony Craig
BIRTHDATE
CURRENTLY IN CUSTODY OF
December 5, 1992
March 15, 1995
Plaintiff/Mother
Plaintiff/Mother
2. A Conciliation Conference was held on May 8, 1996, with the
following individuals in attendance: The Mother, Karen J. Craig, with her
counsel, Andrea C. Jacobsen Esquire, and the Father, Robert E. Craig, II,
,with his counsel, Austin F. Grogan, Esquire.
3. The parties agree to entry of an Order in the form as attached.
/n~ 9 1'1'1(,
Date (I ,
(;" -~d!Ln*:7
Dawn S. Sun ay, Esqu re
Custody Conciliator
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KAREN J. CRAIG,
Plaintiff
IN THE COURT OF <.'llMMOO PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
NO. 96-1666
CIVIL TERM
ROBERT E. CRAIG, II,
Defendant
CIVIL ACTION - LAW
CUSTODY
CIUlI'.R OF cnm
AND tPf, this 30 J~ clay of
upon consideration of the attached Custody
ordered and directed as follows:
~~ ,1997,
ConciHation Report, it is
1. The prior Order of this Court dated May 13, 1996 is vacated
and replaced by this Order.
2. The parties shall submit themselves and the Children to a
custody evaluation to be performed by a professional selected by agreement
of the parties and counsel. The purpose of the evaluation shall be to
assist the parties in determining the best interests of the Children with
respect to the custody arrangements. The Father shall be responsible for
all costs of the evaluation.
3. The Mother, Karen J. craig, and the Father, Robert E. Craig,
II, shall have shared legal custody of Zachary Robert Craig, born December
5, 1992, Leo Anthony Craig, born March 15, 1995 and Hayden Robert Craig,
born July 7, 1996.
4. Pending completion of the custody evaluation and subsequent
order of Court or agreement of the parties, the Mother shall have primary
physical custody of the Children.
5. The Father shall have partial physical custody of the
Children during alternating weeks from Wednesday after work until the
fOllowing Sunday at 8:00 p.m. During the interim alternating weeks, the
Father shall have custody of the Children from Wednesday after work until
Thursday at 8:00 p.m.
The parties agree to reverse the alternating weekend schedule
(Wednesday through Sunday) every 3 months in order that the Children's
custody schedule may coincide with times when the parties' respective
nieces and nephews are also available. Accordingly every three months, the
parties shall alternate having two (2) consecutive weekend pedods of
CIJstody in order to revet:se the schedule. 'I'he Father shall have custody of
the Children over the weekends including January 3, 1998 and January 10,
1998 with the weekends alternating between the parties thereafter under
that schedule until 3 months later, when the Mother shall have a
consecutive weekends over March 28, 1998 and April 4, 1998.
6. The parties shall share or alternate having custody of the
Children on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into
Segment A, which shall begin on Christmas Eve at 12:00 noon
and end on Christmas Day at 11:00 a.m., and Segment B, which
shall begin at 11:00 a.m. on Christmas Day and end at 3:00
p.m. on December 26, when the Mother shall pick up the
Children from the paternal grandmother's residence. The
Mother shall have custody of the Children during Segment A in
every year and the Father shall have custody of the Children
during Segment B in every year.
8. ALTERNATING HOLIDAYS: The Father shall have custody of the
Children from 12:00 noon until 8:00 p.m. in even numbered
years on New Years Day, Memorial Day, Labor Day and
Thanksgiving Day. The Father shall have custody of the
Children from 12:00 neen until 8:00 p.m. in odd numbered
years on Faster Sunday and July 4. In the event the Father's
holiday period of custody falls on a Monday immediately
following his weekend period of custody, the entire period of
custody shall run continuously without interruption.
The Mother shall have custody of the Children from 12:00 noon
until 8:00 p.m. in odd numbered years on New Years Day,
Memorial Day, Labor Day and Thanksgi'ring Day. The Mother
shall have custody of the Children from 12:00 neen until 8:00
p.m. in even numbered years on Easter Sunday and July 4.
C. MOTHER's DAY/FATHER's DAY: The Mother shall have custody of
the Children every year on Mother's Day from 12:00 noon until
8:00 p.m. and the Father shall have custody of the Children
every year on Father's Day from 12:00 neen until 8:00 p.m.
D. CHILDREN's BIRTHDAYS: on each of the Children's birthdays,
the noncustodial parent shall be entitled to have a two (2)
hour period of custody with the Child having the birthday
between 4:00 p.m. and 7:00 p.m.
7. Each party shall be entitled to have custody of the Children
for two (2) nonconsecutive weeks during each summer vacation upon providing
sixty (60) days notice to the other party. The party providing notice
first will have preference for his or her chosen vacation days.
8. The party relinquishing custody of the Children shall be
responsible to provide transportation for exchanges of custody under this
Order. The parties shall insure that the Children are transported in
appropriate car seats.
9. In the event either party is unavailable to exercise his or
her period of custody on an entire weekend, that party shall offer the
other party the opportunity to have custody of the Children during that
time before making arrangements for a third party caregiver.
'"
,.
KAREN J. CRAIG,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
: NO. 96 - 1666 CIVIL
I
I CIVIL ACTION - LAW
:
vs.
ROBERT E. CRAIG, II,
Defendant
IN DIVORCE
ORDER AND NOTICIt SETTING HBARING
TO: Karen J. Craig , Plaintiff
Andrea C. Jacobsen , Counsel for Plaintiff
Robert E. Craig, II , Defendant
Austin F. Grogan , Counsel for Defendant
You are directed to appear for a hearing to take
*
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9 North
Hanover Street, Carlisle, Pennsylvania on the 3rd day
of Anril , 1998, at 9:00 a.m., at which
place and time you will be given the opportunity to present
witnesses and exhibits in support of your case.
E. Hoff r, President Judge
Date of Order and
Notice: 1/16/98
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
CUMBEI~LAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE (717) 249-3l66
* Testimony will be limited to the factor of marital misconduct a.
that factor affects wife's alimony claim.
~
. .
i
KAREN J. CRAIG,
plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 1666 CIVIL
ROBERT E. CRAIG, II,
Defendant
RE: Pre-Hearing Conference Memorandum
DATE: Friday, January 16, 1998
Present for the Plaintiff, Karen J. Craig, is
attorney Andrea C. Jacobsen, and present for the Defendant,
Robert E. Craig, II, is attorney Austin F. Grogan.
A divorce complaint was filed on March 28, 1996,
raising grounds for divorce of irretrievable breakdown of the
marriage. Although an affidavit under section 3301{d) was filed
on December 5, 1997, averring a two year separation from January
10, 1996, counsel have indicated that the parties will most
likely sign and file affidavits of consent prior to the hearing.
The complaint also raised the economic claims of equitable
distribution, alimony, alimony pendente lite, and counsel fees
and expenses. With respect to the alimory claim, counsel have
indicated that they intend to offer testimony on the factor of
marital misconduct which will involve each of the party's
alleged relationships with other persons prior to and after the
separation. There ha~ been some discussion among counsel that
there may be specific testimony that neither of the parties had
any relationships while they were living together; however, that
is not clear and we will entertain whatever testimony the
parties offer on the alleged relationships. In any event,
counsel are directed to provide each other a list of witnesses
at least a month prior to the hearing who will be offered on the
marital misconduct issue.
Wife is in her late 20s and resides at 11 Baltimore
street, Dillsburg, Pennsylvania, with the three children. She
is a high school graduate and works for McDonalds as a fast food
worker. Her attorney indicated that her net biweekly income i.
$280.00. Her medical insurance is currently being covered
through her husband's employer. Wife has not raised any health
issues. She is receiving $168.00 per week in child support and
$50.00 per week for spousal support. Counsel are going to
determine the cost to wife of COBRA benefits through husband'.
employer after the entry of a divorce decree. Mr. Grogan a1.0
indicated that he believes that she is able to get medical
insurance coverage through her employment and he will provide
.
. .
evidence on that matter.
Husband is 29 years of age and resides at 10
Killinger Road, Etters, Pennsylvania 17319 where he lives with a
female friend. He is a high school graduate and works for
Greiner Industries, Inc., as a millwright/welder. His weekly
gross income is $540.00 and adding back in the child and spousal
support deduction, his net weokly it $409.05. He has not raised
any health issues.
Counsel have indicated that there is not any issue
regarding the equitable distribution of assets but there is some
question about some unpaid marital debt involving payments to an
obstetrician that are due and to Met Ed totalling $445.00. Wife
has indicated that she would like husband to contribute toward
the payment of those outstanding bills. Mr. Grogan was not
aware of these bills and asked Ms. Jacobsen to provide him
verification of what is due to the obstetrician and to Met Ed.
Currently the main point of contention in this case
is alimony and the Master inquired as to what wife would like to
have and her counsel indicated $50.00 per week. There is also a
question about the cost to wife for her medical insurance
benefits and Mr. Grogan has indicated that his client did offer
to pay her COBRA benefits for one year.
Because there is probably going to be a number of
persons to testify on the issue of the alleged relationships of
the parties with other persons, we are going to schedule a
separate hearing on the marital misconduct issue for Friday,
April 3, 1998, at 9:00 a.m. Notices will be sent to counsel and
the parties. The testimony will be limited to the factor of
marital misconduct as that factor affects wife's alimony claim.
At that hearing we will determine what date we will need to take
the additional testimony on other alimony factors and counsel
fees.
E. Robert Elicker, II
Divorce Master
CCI Andrea C. Jacobsen
Attorney for Plaintiff
Austin F. Grogan
Attorney for Defendant
.Aud'M g: lll'ft90/l/
ATIORNEY AT LAW
24 N. 32nd Street
Camp Hili, PA 17011
(717)737-1956
December 12, 1997
Mr, Robert Elicker, III
Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Craig v. Craig
Dear Mr. Elicker,
Enclosed please find a time stamped copy of the Notice, Inventory, and Income and
Expense Statement in the above captioned case.
If you have any questions, please contact me at your convenience.
Sincerely,
UllJlZ/~
Austin F. Grogan, Esq.
AFG/rr
enclosure
Cl,:: Robert Craig
j'
,
., ,.,
, I
, '
KAREN J. CRAIG, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
: NO. 96 - l666 CIVIL
VS. :
: CIVIL ACTION - LAW
lUBERI' E. CRAIG, III, :
Defendant I IN DIVORCE
ORDER AND NOTICE SETTING HBARING
TO: Karen J. Craig , Plaintiff
Andrea C. Jacobsen , Counsel for Plaintiff
Robert E. Craig, III Pefendant
,
Austin F. Grogan , Counsel for Defendan t
You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master, 9 North
Hanover Street, Carlisle, Pennsylvania on the 2lst day
,
of July , 1998, at 9:00 a.m., at which
place and time you will be given the opportunity to present
witnesses and exhibits in support of your case.
'rr
',: t:;t. 'mid'" Judg'
Date of Order and
Notice: 413/96
By:
Divorce Master
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET fORTH BELOW TO FIND OUT WHERE YOll CAN
GET LEGAL HELP.
CUMBEHLAND COUNTY B^H MiSOCI^TION
2 L1BEHTY AVENUE
C^HL1SLE, P^ 1'1013
TELEPHONE ('11'1) 24')..]166
WJNSEL m PIVVIDE THE MASTER AND OPRJSING cnJNSEL BY JUNE 22, 1998, A srATDlDll'
OF ISSUES TO BE PRESENfED AND A LIST OF WITNESSES.
EXPENSES:
Week Month Year
(Fill in Appropriate Column)
Home
Mortgage/rent $ $ 100.00 $
Maintenance
Utilities
Electric 70.00
Gas
Oil
Telephone 100.00
Water -
Sewer
Employment
Public trans. $ $ $
Lunch 20.00
Taxes
Real estate $ $ $
Persl. property (land)
Income (Personal)
Insurance
Homeowners $ $ $
Automobile
Life
Accident -
Health
Other (Cancer Ins. )
Automobile
Payments $ $ $
Fuel
Repairs
Medical
Doctor $ $ $
Dentist
Orthodontist
Hospital (Lab)
Medicine ---
Special needs
(glasses, braces,
ortho. devices)
Education
Private school $ $ $
Parochial school
College (ICS course)
Religious
Personal
Clothing $ $ $ I,"~
Food 200.00
Barber/hairdresser 15.00
Credit payments
Charge account
Memberships ,.',
,
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EXPENSES CONTINUED:
Loans
Credit Union
Week Month Year
(Fill in Appropriate Column)
$
--
$
$
Miscellaneous
Household help $ $ $
Child care
Papers/books/mag.
Entertainment
Pay TV $ $ $
Vacation
Gifts
Legal fees
Charitable contrib.
Other child support -
Alimony payments 223.00
Other $ $ $
TOTAL EXPENSES: $
$ ~35.00_
$
PROPERTY OWNED
Checking Accts.
Savings Acets.
Credit Union
Stocks/bonds
Description
PNC
Value
$ ~.OO
OWNERSHIP*
H W J
X
Real estate
Other
IRA
TOTAL:
$
$
.
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ASSETS OF PARTIES
Defendant, ROBERT CRAIG, II, marks on the list below those Items applicable to the
case at bar and Itemizes the assets on the following pages.
() 1.
(Xl 2.
() 3.
() 4.
(Xl 5.
( l 6.
( ) 7.
( ) 8.
( ) 9.
() 10.
() 11.
() 12.
( ) 13.
(X) 14.
( ) 15.
( ) 16.
(X) 17.
( ) 18.
( ) 19.
( ) 20.
( ) 21.
( ) 22.
( ) 23.
( ) 24.
(X) 25.
( ) 26.
Real property
Motor vehicles
Stock, bonds, securities and options
Certificates of deposit
Checking accounts, cash
Savings accounts, money market and savings certificates
Contents of safe deposit boxes
Trusts
Life Insurance policies (indicate face value, cash surrender value and current
beneficiaries)
Annuities
Gifts
Inheritances
Patents, copyrights, inventions, royalties
Personal property outside the home
Businesses (list all owners, including percentage of ownership, and
officer/director positions held by a party with company)
Employment termination benefits - severance pay, workman's compensation
claim/award
Pmfit sharing plans
Pension plans (indicate employee contribution and date plan vests)
Retirement plans, individual retirement accounts
Disability payments
Litigation claims (matured and unmatured)
MilltaryNA benefits
Education benefits
Debts due, including loans, mortgages held
Household furnishings and personalty (includfi! as a total category and ,attach
itemized list if distribution of such assets is in dispute
Other
......l
"
MARITAL PROPERTY
Defendant lists all marital property in which either or both spouses have a legal or
equitable interest individually or with any other person as of the date this action was
commenced:
Item Description of Property Names of All Owners
Number
2. 92 Dodge Dakota Robert Craig & Karen Craig
2. 94 Mazda Robert Craig & Karen Craig
25. Dining Room Suit Robert Craig & Karen Craig
25. Curtains Robert Craig & Karen Craig
25. Zachary and Tory's Room (All Clothes, Robert Craig & Karen Craig
Toys, Beds and Dressers)
25. All outside toys, swingset, riding toys, Robert Craig & Karen Craig
sandbox
25. living Room Furniture (Two lamps, Robert Craig & Karen Craig
Curtains, Nic-Naks, Couch and love
Seat)
25. Kitchen (Two Sets of Dishes, Robert Craig & Karen Craig
Silverware, Microwave, Coffee Pot)
25. Waterbed, Two lamps Robert Craig & Karen Craig
25. Miscellaneous (Antique Mailbox, Robert Craig & Karen Craig
Antique Folding Church Pew, Nic-Naks
a'ld pictures)
25. living Room Furniture (Two lamps, Robert Craig & Karen Craig
Curtains, Nic-Naks, Couch and love
Seat)
. I ...... I. ..'
LIABILITIES
Item
Number
Description or Property
Names of All
Creditors
Names of All
Debtors
.','
....
KAREN. CRAIG,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
ROBERT CRAIG, II
Defendant
: NO. 96.1666
: IN DIVORCE
PROOF OF SERV~
I, Austin F. Grogan, Esquire, hereby certify that onO>>)~ 1997, I served a
copy of the Defendant's Inventory by first class mail, postage prepaid addressed as follows:
Andrea Jacobsen
JACOBSEN & MILKES
52 East High Street
Carlisle, PA 17013
Date:
,,f).(.l /1{7
.
"
Samuel W. Mllkes
Andrea C. Ja~'Obsen
JACOBSEN & MILKES
52 East High SUeet
Carlisle, PA 17013-30!l5
Tel 717 249.6427
FIllI 717 249-!l427
July 29, 1996
E. Robert Elicker, II
Office of Divorce Mt\8ter
9 North Hanover Street
Carlisle, PA 17013
RE: Karen J. Craig v. Robert E. Craig, II
No. 96-1666
Dear Mr. Elicker:
Thank you for your letter of July 25, 1996, regarding your Appointment DB
Master in the above-referenced divorce proceedings. I am writing to advise you that
Mrs. Craig is not willing at this time to sign an affidavit of consent, and the parties
have not been separated for a period in excess of two years. I'm not aware that Mr.
Craig has raised a fault claim in this matter. Accordingly, I do not believe that there
are grounds at this time for this matter to proceed to a Master's hearing. Under the
circumstances, will you please advise whether or not the requested pre-trial statement
will be due on the schedule set forth in your letter.
Thank you for your attention to this matter.
Sincerely,
ACJ\jlc
cc: Austin F. Grogan, Esq.
Karen J. Craig
7
!
(corr)072gelic.cra
KAREN J. CRAIG, IN THE COURT OF COMMON PLEAS OF'
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACT ION ... f.AW
vs. NO. l666 CIVIL 19 96
ROBER'r E. CRAIG, I I.
Defendant IN DIVORCE
DATEI
7/25/96
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STATUS SHEET
ACTIVITIES:
Pretrial statements are due on or before 8/l6/96.
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Prehearing set by the Master's Office for l/l6/98, at
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OFFICI OF DIVORCI MASTIR
CUMBERlAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carllslo. PA 17013
(717) 240.6535
I. lIolM.. IlIeker, II
Dlvorc. Mast.r
Tr.el "0 Col~ur
Offlc. Manager/R.porter
We.t thoro
697.0371 Exl. 6535
July 25, 1996
Andrea C. Jacobsen
Attorney at Law
JACOBSEN & MILKES
52 East High Street
Carlisle, PA 17013
RE: Karen J. craig VB. Robert E. Craig, II
No. 96 - 1666
In Divorce
Austin F. Grogan, Esquire
24 North 32nd Street
Camp Hill, PA 17011
Dear Ms. Jacobsen and Mr. Grogan:
By order of Court of President Judge Harold E. Sheely
dated July 23, 1996, the full-time Master has been appointed in
the above referenced divorce proceedings.
Please note that the caption on the order appointing
Master is incorrect designating Robert Craig as the Plaintiff
and Karen Cra ig as the Defendant. 'lhe divorce complaint and
other pleadings in the file show Karen Craig as the Plaintiff
and Robert Craig as the Defendant.
A divorce complaint was filed on March 28, 1996, raising
grounds for divorce of irretrievable breakdown of the marriage
and the economic claims of alimony, alimony pendente lite,
counsel fees, costs and expenses, and equitable distribution.
The motion for appointment of Master specifies distribution of
property as the only economic issue; however, since other claims
have been raised in the pleadings, I will address all claims.
I am unable to determine from the file whether or not the
parties are willing to sign affidavits of consent or if the
parties have been separated for a period in excess of two year..
However, I am going to proceed on the basis that grounds for
divorce are not at issue and in accordance with P.R.C.P.
1920.33(b) I am directing each counsel and to file a pre-trial
.
Ms. Jaoobsen and Mr. Grogan, Attorneys at Law
25 July 1996
paqe 2
statement on or before Friday, August 16, 1996. Upon receipt of
the pre-trial statements I will immediately schedule a
pre-hearing conference with counsel to discuss the issues and,
if necessary, schedule a hearIng.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE I Sanctions for failure to file the pre-trial statements
are set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.