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HomeMy WebLinkAbout96-01847 . . . . .... ..'...... .:co -=-:. 0:+:0'" -:c- ..),.;. ':CO .:.:. .:.:. -:c. .:.:. .:.:. .:.> .:+:. .:.:.-) '.:+:.:'.:c.::.....:~.-...... '.~ 0;<<0 (Co' "*".~ ~ --- ~- .--. . ~ 8 $ IN THE COURT OF COMMON PLEAS e 8 8 8 OF CUMBERLAND COUNTY 8 ~ * 8 8 8 . STATE OF ~"~~. ,;1- I PENNA. 8 e 8 8 8 8 8 . KIRBY E. BOOIIER, Plaintiff i\: II." "",.,.,.,1.1147............. (996 ~ 8 $ \'1'1'"", e 8 8 e TINA L. DOOIIER, Defendant 8 e 8 8 ~ e DECREE IN e ! D I V 0 R C E u'r ~ ~ ~ b o:t ...,. ~S' I'~' . 8 i AND NOW, ,..,..~ ..~,~,........ 1999..... It Is ordered and 8 ~ decreed that..,... ,~~~!3.Y. ,~,. ,B.qQf:lf:,R,........,......,....,.... plaintiff, ~ ~ ~ ~ and. .... , .. ,~~~.A..~: ..B.q'?~!'-l.R. . .... .. . ..... .. . . .. ... , ,.. ....., defendant, ~ ~ are divorced from the bonds of matrimony. $ 8 ^ ~ The court retains jurisdiction of the following claims which have : 8 been raised of record In this action for which a final order has not yet ~ ~ been entered; ::. ~." ~ " W lit " .... .,.,. .,.. .,. "" .0....".. .... II.. ,....... II.. ,. ... .,t ..... .... to "" '0' f.' ,', ~ $ ~ ~ $ . ~ 8 ::: ,; AII..I' ~ J ~ ~ . !~ 8 I; n I'rnlhnllnlnry I ~ ~ -----.-.. .............-..-...........-... ~ ._-. , .. '~ . ~~~~_~~._~*~**~*'~'*'~'~'**'~**ID~'~* . '. /.J.JI. (ld If). 'V"-' IV, Y)' dlt/. ,1?y' ~1I....d~ c;. .;?f (';:-,,;.:)'"/ ~~".1,.;. ;4,-...Ii~ ./ .1/r'. . . ~ . . KIRBY B. BOOHER, I IN THE COURT OF COHMON PLEAS plaintiff I CUHBBRLAND COUNTY, PENNSYLVANIA I v. I NO. 1847 lUll I TINA L. BOOHER, I CIVIL ACTION - LAW Defendant I IN DIVORCE I PRAECIPB TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: July 26. 1999: Certified/Restricted Delivery. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, N/A ; by Defendant, N/A . (b) (1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: 10/26/99. (2) Date of filing and service of the affidavit upon the respondent: 11/15/99 4. Related claims pending: All claims were withdrawn by Order dated July 30. 1999. KIRBY B. BOOBD, I IN TBI COURT OW COHMON PLBaB plaintiff I CUHBIRLAND COUNTY, PIlIOI8YLVUIA I v. I HO. 1847 UU I TINA L. BOOBD, I CIVIL ACTION - LAW Defendant I IN DIVORCB I . (~ I.:~'\ '.'.' .... \ . I-n If you wiBh to deny any of the allegation. ..t forth ip': this,; affidavit, you must fUe Il counterclaim within tventy(20) \ day..? af~81' this affidavit has been .erved on you or the alleqat1on.'1fil1~;\ be a4llitted. " . -;', 1(\ ."'\ . I '.. ~~ .,., ~ 0'" NOTICI TO DBI'INDAHT Al'I'IDAVIT 01' PLAINTII'I' UNDIR SICTION 330114' 01' TRI DIVORCB CODB 1. The parties to this action separated on January 1, 1996, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. Section 4904 relating to unsworn falsification to authorities. Date: 1~~&'1/99 ~c::7 K RBY E. BOOHER, Pla .. KIRBY B. BOOHER, I IN THE COURT or COHMON PLBAS Plaintiff I CUHBBRLlUm COUNTY, PENNSYLVANIA I v. I NO. 1847 lUll I TINA L. BOOHER, I CIVIL ACTION - LAW Defendant I IN DIVORCE I PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: July 26. 1999: Certified/Restricted Delivery. 3. Complete either paragraph (a) or (b). (a) Date of exeoution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, N/A ; by Defendant, N/A (b) (1) Date of execution of the affidavit required by Seotion 3301(d) of the Divorce Code: 10/26/99. (2) Date of filing and service of the affidavit upon the respondent: 11/5/99(fi1ing date! , 11/15/99 (date Qf service upon respondent). 4. Related claims pending: All olaims were withdrawn by Order dated Julv 30. 1999. . . 5. complete either (a) or (b). (a) Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: liLA. (b) Date Plaintiff's Waiver of Notice in section 3301(c) Divorce was filed with the prothonotary: N/A Date Defendant's Waiver of Notice in section 3301(c) Divorce was filed with the Prothonotary: N/A By: I - f "'~.__ t."\... . C.,\, \" Joanne Harrison Clough, Esquire 845 Sir Thomas court)JSuite 11A Harrisburg, PA 17109 (717) 540-5100 Id. No. 36461 Dated: \ 2.. \.; .,,~ -, I I , I , f" :1 . :\ i ,'II ,: I ~1 1, '.. ::) ~ h- ," - 1- .-~ ~; d L: '- :> 'i:j " ... ~ "i'iJ , J{J.. (fJ ( . j I , " .J ,\ , -, )".'I#yp-..-til" . I" ,. e: I .. " ; ( i ~ . ,~, : t.i' , ' , ~ i , I I " I' ..-," I , '. , "..,.,r/'tl) , , (f & 'J . r:' , ,! , ! , , fllj ! '" -'. t --- - II: If) I ~: ~ " '" , ' to> .. c:t '.' I. t'''': .' j ~ , ':] . . ~ ,~ II t... ~ , J !"'" f-' .' C] .. I ,',\ ~ L." ; () 1 . i l' . , ~. ~ " \) ',1 (-, , i ~ -- ~ ~'. U . "71 ~ -6;: d 0!. .~ .... . ..J!:.1 ~ ........ 1 J ~ :::- ~ <( - :5= frtc u :::l 1;25 ~ ::E ~~~8 ~ ~ a ~~ ..s:: .. ~ "j::' gp~F1E. o i:i .":1: o s~ , , ". " , , v. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ,~ 1996 - IP"I?-~lJ,'l k/2../'1 CIVIL ACTION - LAW IN DIVORCE KIRBY E. BOOHER, Plaintiff . . TINA L. BOOHER, Defendant MOTION TO INCLUDE EOUITABLE DISTRIBUTION TO DIVORCE COMPLAINT AND NOW, this /.:3rS day of '=j)(.. l <i2.~\)('.r- , 1998 comes the Plaintiff, by and through his attorney, Joanne Harrison Clough, Esquire and respectfully avers as follows: 1. A Divorce Complaint in the above captioned matter waB filed on April 8, 1996 with the prothonotary of Cumberland county, Pennsylvania. 2. At the time the Divorce Complaint was filed, equitable distribution was not included as an issue. 3. Plaintiff, Kirby E. Booher now wishes to raise equitable distribution as an issue in the divorce action. WHEREFORE, Plaintiff respectfully requests that equitable distribution be heard by the Special Master at the Master' B Hearing, which has not yet been scheduled. Respectfully Submitted, Jo 845 Sir ThomaB Harrisburg, PA (717) 540-5100 Id. No. 36461 " ..... U'l ",h 1.1: l,': I~; I~~' .. , . " I ~ ; C,) }" . ,," iO , ,. '; j I III i .. I: r~. .' L.1.,' f', , . .' . '!l ~ , " 'I " . " '. . II ('1> i I .. (;'1 i.J -;b ::I < O~:S - - - U l(.~g ~- -I" ~t::~ .g 8~~ 8 a ~~ ~~~lE Q) lii''':I: =ia~ =l(O!i C':l o ..... . . ... v. IN THE COURT OF COMMON ~LEAS CUMBERLAND COUNTY, PENNSYLVANI~ NO. 1847 1996 KIRBY E. BOOHER, Plaintiff TINA L. BOOHER, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER TO WITHDRAW ALL ECONOMIC CLAIMS AND NOW, this ~~ day of _~ ' 1999 upon review of the attached Motion, it is hereby ORDERED and DECREED that all economic issues be withdrawn from this divorce action. ,J. I~ ~~ , ~ j '~~J 111\ ::'1 hi ,: 1~'1 C'" ....' ::;,,( Fe:;"! ,d"(t\ , KIRBY E. BOOHER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1847 1996 v. TINA L. BOOHER, Defendant CIVIL ACTION - LAW IN DIVORCE VBRIPICATrON I, Kirby E. Booher, verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: 7-,z)'7? ~<0] KIR~'l E. BOOHER KIRBY B. BOOHBR, I IN THB COURT OF COMMON PLBAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 1847 1996 I TINA L. BOOHBR, I CIVIL ACTION - LAW Defendant I IN DIVORCB I CBRTIPICATB OF SERVICB AND NOW, this ~ day of ~~ ' 1999, I, Katherine A. Hornyak, Secretary to Joanne H. Clough, Esquire, Attorney for the Plaintiff, Kirby E. BOOher, hereby certify that a copy of the within document has been served, by depositing a copy of the same in the United states mail, first class, postage prepaid, certified/ Restricted delivery at Harrisburg, Pennsylvania, to the following addressee: Tina L. Booher 28 Michelle Avenue, #28 Leesburg, FL 34748 By: KIRBY E. BOOHER, plaintiff I IN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA :NO. 1~'- /[f 7 CIVIL ICIVIL ACTION - LAW tIN DIVORCE vs. TINA L. BOOHER, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TARE 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. COURT ADMINISTRATOR, THIRD FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA TELEPHONE: 240-6200 Low orne.. Dunenn & Otto, P.C. KIRBY E. BOOHER, Plaintiff I IN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA . ;NO. '}(,. - IJ'y? CIVIL ICIVIL ACTION - LAW IIN DIVORCE vs. TINA L. BOOHER, Defendant COMPLAINT AND NOW COMES the above-named Plaintiff, by his attorney, Susan J. otto, Esquire, and makes the following Complaint in Divorce I 1. Plaintiff is Kirby E. Booher, a sui juris adult who currently resides at 520 Shed Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Tina L. Booher, a sui juris adult who currently resides at 1550 Williams Grove Road Lot 104, echanicsburg, Cumberland County, Pennsylvania 17055. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for a least six onths immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on May 24, 1993 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken 7. Plaintiff has been advised of the availability of arriage counseling and the Plaintiff may have the right to equest that the Court require the parties to participate in ounseling. WHEREFORE, Plaintiff prays this Honorable Court enter its decree divorcing the parties. Respectfully submitted Low orne.. Dunenn & Otto, P.C. tto, Esq. ow CarliSle, PA 17013 (717) 249-7780 , IRBY E. BOOHER, plaintiff tIN THE COL~T OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : "'Go _If'!? : NO," CIVIL ~ : CIVIL ACTION - LAW :IN DIVORCE vs. INA L. BOOHER, Defendant AFFIDAVIT Kirby E. Booher, Plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand t.hat I may request that the Court equire my spouse and I participate in counseling. 2. I understand that the Court maintains a list of arriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I t9Q{DO NOT) request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.4904 relating to unsworn falsification to authorities. ~~ ~ f?/~.L' KIRBY E~ BOOHER (,nw Oll1rl'. Ounenu & OlIn. 1'.(:. ,t" ff NOTICE OF AVAILABILITY OF COUNSELING KIRBY E. BOOHER, Plaintiff vs. TINA L. BOOHER, Defendant IN DJ:VORCE To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with section 202(C) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover street, CarliSle, Pennaylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be born by you and your spouse. J:f you desire to pursue counseling you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Lawrence E. Welker Prothonotary Low Omel'. Dunenn & Otto, P.C. r~ 0 o. f.' (>,..1 , UJ~. : .. l...}'" ,'oj , , :~:; &:' \-... .' . l.-' (11" i <:.I 1.1..:(." I , ~l_' , r I.' , .ij ". ,-: ;a. () '" ;~J toil l.) ~ Y)~ I" .......... p ~ ~ "'l ~ ~ '- ^' l'- ~....~ A\J ,4 "<'- .... ..... ,...... ~ .~ c:J~ ...- -.- (') '.. l( \-' ~ ., .i:. ,oJ :''"?-:$ ,- t ,). -os ~-. .) "'1. "~ " (~. ~'. (1;' :~~ L1o. I \',1(6 11- ~\\~ l'~ .' ,c.. ,:.. ;;, I ~1 3 I" ~ <:) E~~ 8-lC ,!IE ::s::l oilEs ~!!~~ OJ p~,::' "Eh~~~E. ::s ~ ill ~ o ~~ ~. """ \- --- r-. ..,..,. _ m"~. __.. Clough & Murphy ^mlRNfiVS A C'UUNSfiUlRS ^T lAW 845 Sir 'P---" r.UII, Sullo IIA Illrrl.hu1a, PA 17109 (717) 540,5100 KIRBY B. BOOHBR, I IN THB COURT OF COKHON PLBAB OF .,{,-, plaintiff I CUMBERLAND COUNTY, PBNNBYLVANIA f^ I v. I NO. 9tS - 1847 CIVIL I TINA L. BOOHBR, I CIVIL ACTION - LAW '. Defendant I IN DIVORCE t.' .";'. ;.- AFFIDAVIT OF ACCEPTANCE OF SERVICE I, L/AltlSIOI/ ))/QR;:' ~u~ Esquire, accept service of the Complaint in Divorce. I certify that I am authorized to accept service on behalf of the Defendant. (, , .,-- -~ , c'/. ~/ v.' ~\',- ,_.'~ r:\' if' Y3 r ~~ '. :..\f. ~;..' ~_.; Date: 3-.2J.j-17 .~~~a,~~ i ~~indsay D. ~aird, Esquire l/ V - ," '0 '- " " .. , .~ (0; , , , , , .. " "" i ;- ~I , " , .. , , , , ? I J , r ,) , '.1. V. , C', .J , , C , ;-) - .. , . ..c b.O == < o~- O~!2; c= .. cil!:: 8 o ~ 5 - 'S ~ a ~i ctl oil ~... ~ ::r: ~ F: .~ is ll) aI,to: s~~ ctl o -. KIRBY E. BOOHER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 1847 1996 . . TINA L. BOOHER, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OP DIVORCE DECREE TO: TINA L. BOOHER You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counteraffidavit to the Plaintiff's affidavit. Therefore, on or after October 8, 1999, the Plaintiff can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court /in Answer with your signature notarized or verified or a Counteraffidavit by the above date, the Court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 KIRBY E. BOOHER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1847 1996 CIVIL ACTION - LAW IN DIVORCE v. TINA L. BOOHER, Defendant COUNTBR-APPIDAVIT UNDER SBCTION 33011dl OP THB DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a Divorce Decree. (b) I oppose the entry of a Divorce Decree because Check (i), (il) or both): The parties to this action have not lived separate and apart for a period of at least two (2) years. ____ (ii) The marriage is not irretrievably broken. ____ (i) 2. Check either (a) or (b)l ____ (a) I do not wish to make any claims for economic relief. 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. I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. ____ (b) I verify that the statements made in this Counter- Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. Date: TINA L. BOHER, Defendant NOTICE. If you do not wish to oppose the entry of a Divorce Decree and you do not wish to make any claim for economic relief, you need not file this Counter-Affidavit. " . , . .~ KIRBY B. BOOHBR, I IN THB COURT OF COMMON PLBAB plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 1847 1996 I TINA L. BOOHBR, I CIVIL ACTION - LAW Defendant I IN DIVORCB I CBRTIPICATE OP SERVICB AND NOW, this day of ~, 1999, I, Katherine A. Hornyak, Secretary to Joanne H. Clough, Esquire, Attorney for the plaintiff, Kirby E. Booher, hereby certify that a copy of the within document has been served, by depositing a copy of the same in the United states mail, first class, postage prepaid, certified/ Restricted Delivery and certificate of Mailing at Harrisburg, Pennsylvania, to the folloldng addressee I Tina L. Booher 28 Michelle Avenue, #28 Leesburg, FL 34748 By: -,' Kirby's SS H275-78-4343 Tina's SS H591-72-6273 ~ I I . . 'l, ',JJ" {. \: f:. .~ ': r' I " .. I , .. ~ '. \' ( . .. . , '.[.~ t. " ......-~... " , J " , ., , \ " , j,. ! \, \~ .. I' .' I ,,' i r ~ .I"" I ','1 , , i , ~,: " I . i ..,~.. \ .' , ( , I " I :, , jl J.' . ,\ i ;.. \ " I .. I Iii . KIRBY II. BOOHD, I IN THII COURT 01' COMMON l'LIlAS Plaintiff I CUHBBRLAND COUNTY, PBNNSYLVUfIA I v. I NO. 1847 19911 I TINA L. BOOHIlR, I CIVIL ACTION - LAW Defendant I IN DIVORCIl NOTICB TO DBPBND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary, Dauphin county Courthouse, Front and Market Streets, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ItIltBY II. BOOBIIR, I IN TBII COURT OF COHKON PLIlAB Plaintiff I CUMBJ!RLAND COUNTY, PBNNBYLVPIA I v. I NO. 1U7 19915 I TINA L. BOOBIlIt, I CIVIL ACTION - LAW Defendant I IN DIVORCII UBHDRD COMPLAINT IN DXVORCR mmRR BRCTXON 3301/D\ OF TRR DIVORCR CODR AND NOW, comes the plaintiff, KIRBY E. BOOHER, by and through his attorney, Joanne Harrison Clough, Esquire, and files this Amended complaint in divorce seeking to obtain a decree in divorce from the above-referenced Defendant pursuant to Section 3301 (d) of the divorce code and sets forth the following: DXVORCB 1. Paragraphs one (1) through seven (7) of the original Complaint in Divorce filed April 8, 1996, is incorporated herein by reference thereto. 2. Plaintiff and Defendant separated on or about January 1, 1996, and have lived separate and apart for a period of at least two (2) years. WKJRBrQRB, plaintiff requests your Honorable Court to enter a Decree in Divorce divorcing plaintiff and Defendant under section 3301(d) of the Divorce Code. Respectfully submitted, Dated: 7../07---<(,_ f i I i , ;1 , ; f KIRBY E. BOOHER, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1847 1996 . v. TINA L. BOOHER, Defendant CIVIL ACTION - LAW IN DIVORCE VIIRI.ICI\.TIOH I, Kirby E. Booher, verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authoritIes. Dated: 7-,'10 -99 .r..4..f... KIRBY II. BooBIIR, I IN TBI COURT OF COKKON PLIAS Plaintiff I CtlHBlRLMl'D COUNTY, PBNNBYLVUlIA I v. I NO. lU7 19U I TINA L. BOORD, I CIVIL ACTION - LAW Defendant I IN DIVOROI I CIIRTIFICATB or SBRVICB AND NOW, this ~day of A. Hornyak, secretary to Joanne , 1999, I, Katherine Esquire, Attorney for the Plaintiff, Kirby E. Booher, hereby certify that a copy of the within document has been served, by depositing a copy of the same in the United states mail, first class, postage prepaid, Certified/ Restricted delivery at Harrisburg, Pennsylvania, to the following addressee: Tina L. Booher 28 Michelle Avenue, #28 Leesburg, FL 34748 By: /, /J - L if!. . tf:::L_. J.A '- . ~~A. Hor~;k'2f~' KIRBY E. BOOHBR, I IN THE COURT OF COMMON PLBAB plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 1847 1996 I TINA L. BOOHER, I CIVIL ACTION - LAW Defendant I IN DIVORCE NOTICE TO DEPEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the prothonotary, Dauphin County Courthouse, Front and Market streets, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER I S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 KIRBY B. !lOOHBR, I IN THB COURT OF COMMON PLBAB plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. : NO. 1847 1996 I TINA L. BOOHBR, I CIVIL ACTION - LAW Defendant I IN DIVORCB AMENDED COMPLAINT IN DIVORCB UNDBR SBCTION 3301'01 OP THE DIVORCB CODB AND NOW, comes the Plaintiff, KIRBY E. BOOHER, by and through his attorney, Joanne Harrison Clough, Esquire, and files this Amended Complaint in divorce seeking to obtain a decree in divorce from the above-referenced Defendant pursuant to Section 3301 (d) of the divorce code and ssts forth the followingl DIVORCE 1. paragraphs one (1) through seven (7) of the original Complaint in Divorce filed April 8, 1996, is incorporated herein by reference thereto. 2. plaintiff and Defendant separated on or about January 1, 1996, and have lived separate and apart for a period of at least two (2) years. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1847 1996 CIVIL ACTION - LAW IN DIVORCE KIRBY E. BOOHER, plaintiff TINA L. BOOHER, Defendant VBRIPICATION I, Kirby E. Booher, verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.s. section 4904 relating to unsworn falsification to authorities. Dated: 7-....~O - 99 .:1.1'.[.:: " -i- KIRBY B. BOOHBR, I IN THB COURT OF COMMON PLEAS plaintiff I CUMBBRLAND COUNTY, PENNSYLVANIA I v. I NO. 1847 1996 I TINA L. BOOHER, I CIVIL ACTION - LAW Defendant I IN DIVORCE I CBRTIFICATB OP SERVICE AND NOW, this ~day of A. Hornyak, Secretary to Joanne , 1999, I, Katherine Esquire, Attorney for the Plaintiff, Kirby E. Booher, hereby certify that a copy of the within document has been served, by depositing a copy of the same in the United States mail, first class, postage prepaid, certifiedl Restricted delivery at Harrisburg, Pennsylvania, to the following addressee I Tina L. Booher 28 Michelle Avenue, #28 Leesburg, FL 34748 By:. ~1A'^'-"LA.cPL~'J.A'. ~~~In';'A. Hor~;kOc r , .. ~..._.l KIRBY B. BOOHIlR, I IN THB COURT OF COMMON PLEAS plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. 1847 1996 I TINA L. BOOHIlR, I CIVIL ACTION - LAW Defendant I IN DIVORCB I APPIDAVIT OP SBRVICE Joanne H. Clough, Esquire, being duly sworn according to law, deposes and says that she is an attorney at law duly authorized to practice in the commonwealth of Pennsylvania, and that on the 26th day of July, 1999, she did serve upon Defendant, Tina L. Booher, in the foregoing case, a true and correct copy of the Amended Complaint in Divorce by sending a copy by certified Mail, Restricted Delivery, postage pre-paid, to Tina L. Booher, the Defendant. The receipt for said Complaint is attached. Said copy of the Complaint was duly endorsed with notice to Defendant to appear and answer within twenty (20) days from the date of service or the matter would proceed without her. Sworn to and sub~qribed belt me this ...JS;L...day of. W.' 'h b.,^ , 1999. ~.,.. ~ d'~''''6,f o a y Pub' c' "U"WIW ,~'::. A.....AI\, ~.. -.. ~I 'rr.,.. .... ClIiIt,M .~..... .. *'1, :of-' ._~..:.....~ BYI Joanne Harr son Cloug 845 Sir Thomas Harrisburg, PA (717) 540-5100 Id. No. 36461 . ", SENDER: ' 11110 wtahlo receive the .~_'''-I''''__ '- 1oI1owtogHrvlcM(Ioran I :~~= :;:-=On"_"'''''''';;''~''__'' Ixtra tH): I .r.:""r:'ionnlo.._",..~,..""...._NOPOOO_nol 1. i . .er.::.__~""..._boIow"--' j , I . ~ RICIIpt wi IhOW to whom IN .,.... dIIIYefId IIld Iht dItI CanIU I & 3. Ar1ldI Addrellld 10: .1, MlcII Num r I Tinn L. Boohcr 4b~rv\cI Type 0 ~ ( 28 Michcllc Avcnuc, 1128 0 Reglalllld I Lccsburg, FL 34748 0 exprl" MIll I o Relum~lorMon:l1lndlN 0 COD 1 ::X;!OIU~ 1 s. 7=:'': J I- ................ Domestic Retum Receipt . kr'fv-f~l R~I!Ul~~ (hf\',i.:/ us Poslol SONic. r ~~celpt for certlhed Mall Tinn L. Boohcr 28 Michcllc Avcnuc. 1128 Lccsburg, FL 34748 POltAlJe $ CertJ'l&dreG Spooal Oehery rfttl noslndnd Oehflry reo '" ' g: Oalum AecOIpl Sho"" tu .... \""hom" O"le (Mh111 d . ~ ANnR.~soo.OJ J\!l -t OJlt,lMhm"'IMtm ~ TOTAL Postlge & r~,.., C') Postmaftl III V.le ~ ..~ --~ :r -} i ... Cl -- ) ~ (:; I,,, .. '. , " (', .:r - ) ~ :: ~'" , ':'.1"'" ). ~ ''': , ' ", u.. \ ~.:; ., l~} , , \0 " ;" I ~.; '. C. iljj t, , "J.. C. a " r.:~ ( - (,' ') " ~ ~ ..., ) ) KIRBY E. BOOHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96 ~ 1847 vs. CIVIL ACTION ~ LAW TINA L. BOOHER, Defendant IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Kirby E. Booher , Plaintiff Joanne H. Clough , Counsel for Plaintiff Tina L. Booher , Defendant Lindsay D. Baird , 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 Hanover Street, Carlisle, pennsylvania on the of at place and time you will be given the witnesses and exhibits in support of your caGe. North day a.m., at which opportunity to present · ',tr" Eor:t Pres iden t Judge Date of Order and Notice: By: Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO on TELEPHONE TilE OFFICE SE" FOR"H BELOW TO FIND OUT WHERE YOU CAN GET LEGAl, IlELP. CUMOEnLANn cOUNTY BAil ASSOCIATION I. LIIIEIl'l'Y AVENUE CAIlLI!;LE, PA 17013 'l'ELEI'1I0NE ('I 1'1) 24') - 31 hfl LINDSAY DARE BAIRD ATTOIINHY AT LAw 0' SOUTH !lANOVEII CAHLISLE. PEHNSYLVANIA 170HHI:I07 ,.1- (717) 2oIt\oll702 'AX (717) ~'IU'1I110 February 4. 1999 E. Robert Ellcker.1I Office of Divorce Master 9 North Hanover Street Carlisle, PA 17013 RE: Booher v. Booher No. 96-1847 Dear Mr, Elicker: I have not been represenllng Ms. Tina L. Booher since April, 1998. Thank you for your allenllon to this mailer. Very truly yours, ~)'^~ . K<')Ut/I'( _ . Indsay Dare Baird. Esquire LDB/ml (;; '" ~ .; r(~ , I)/r? ('; , h5. ~( 1.... (-I)! (;11/' r'J 'I' I fro ,. r'_' 'I rl. I" .1 l.. ., (n 1 U L') U >.;J < .Cl :s ::: frtc ,l! 2: = ::! oil;:: 8 "'=' ! ll-- ~ 8~~ ~ pl'~ fn~F1E. = i ,\>:I: O~~ - Ch U .. .. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1847 1996 CIVIL ACTION - LAW IN DIVORCE KIRBY E. BOOHER, Plaintiff TINA L. BOOHER, Defendant PRE-TRIAL STATBMENT AND NOW, this c9!I day of chnllQ^(t , 1999, the Plaintiff, Kirby E. Booher, by and through his attorney, Joanne Harrison Clough, Esquire files this pre-Trial Statement as follows I I. MARITAL PROPERTY See Inventory and Appraisement, filed simultaneously with this Pre-Trial Statement. II. EXPERT WITNESSBS None to date. III. OTHER WITNESSES Kirby Booher. IV. EXHIBITS All exhibits which will be submitted at the time of hearing are described as folloWSI a. Master Card statements b. Beldon Jewelers Statements c. Sears Statements d. BOscov's statements e. Beneficial Statements f. Cornerstone Credit union Statements g. PNC documents regarding repossessed corsica automobile h. American General Finance Documents I. commercial Credit Loan Statements j. AT&T Master Card Statements k. Other documented evidence of joint debt husband paid post-separation . ':I. INCOME Plaintiff I s income is set forth on the Income and Expense statements filed simultaneously with this pre-Trial statement. His weekly gross earnings are $757.56 for a weekly net pay of $534.59. It is unknown if the Defendant Wife is presently employed. VI. PENSION/RBTIRBMBNT It is believed Defendant has no pension. ':III. MARITAL DBBTS Although the parties had a brief marriage, the parties had substantial marital debt of credit card and other loans in excess of $15,000.00. VIII. PROPOSED RBSOLUTION A 3301(d) no fault divorce should be granted. Plaintiff ahould be given credit in equitable distribution for the substantial joint debt he has paid on behalf of the parties since separation. Wife should be responsible for the commercial Credit debt of $6,080.20 since it was incurred for loan for furniture she has in her possession and other items she received from this loan. Wife should be responsible for the balance due to the repossession of the Corsica vehicle and for the AT&T Master Card debt. Respectfully SUbmitted, Clough, Esqu e court, suite 11A 17109 . KIRBY E. BOOHER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1847 1996 CIVIL ACTION - LAW IN DIVORCE v. TINA L. BOOHER, Defendant VERIPICATION I, Kirby E. Booher, verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities. Dated: #7 ( ( ( ( ) ( ) ( ) ( ) ( x ) ( x ) ( , I ) ) 17. Profit sharing plans 18. Pension plans (indicate employee contribution and date plan vests) I !-i " tl , " p .. !! ) 19. Retirement Accounts plans, Individual Retirement ) 20. Disability payments 21. Litigation claims (matured and unmatured) 22. Military/V.A. benefits 23. Education benefits 24. Debts due, including loans, mortgages held 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) 26. other: Deferred Compensation Program 'I 1 MARITAL PROPBRTY PLAINTIFF LISTS ALL MARITAL PROPERTY IN WHICH EITHER OR 80TH SPOUSES HAVE A LEGAL OR EQUITABLE INTEREST INDIVIDUALLY OR WITH ANY OTHER PERSON AS OF THE DATE OF THE SEPARATION OF THE PARTIEBI ITEM DESCRIPTION NAMES OF DATE OF NUMBER OF PROPERTY ALL OWNERS ACQUISITION 2. Corsica Husband & Wire Repossessed in 1996 25. Furniture Husband & Wife ITEM NUMBER COST OR VALUE AS OF DATE OF ACQUISITION VALUE AS IF DATE ACTION COMMENCED AMOUNT OF ANY LIEN ITEM NUMBER NATURE OF ANY LIEN EFFECTIVE DATE OF LIEN HOLDER OF LIEN LIABILITIES OP PARTIBS plaintiff marks of the list below those items applicable to the case at bar and itemizes the liabilities on the following pages: Secured ( ) 1. Mortgages ( XX ) 2. Judgments ( ) 3. Liens ( ) 4. other secured liabilities Unsecured ( XX ) 5. credit card balances ( ) 6. Purchases ( XX ) 7. Loan payments ( ) 8. Notes payable ( ) 9. Other unsecured liabilities contingent or Deferred ( ) 10. Contract or agreements ( ) 11. Promissory notes ( ) 12. Lawsuits ( ) 13. options ( ) 14. Taxes ( ) 15. other contingent or deferred liabilities LIABILITIES plaintiff lists all liabilities of either or both spouses along with any person as of the date this action was commenced: ITEM DESCRIPTION NAME OF ALL NUMBER OF LIABILITY CREDITORS DEBTORS 2. Judgement Husband and Wife commercial credit 2. Judgement Husband and Wife American General ITEM NUMBER DATE LIABILITY WAS INCURRED AMOUNT OF LIABILITY ON DATE INCURRED & ACTION WAS COMMENCED 2. During marriage During marriage $6,080.20 844.12 2. ITEM NUMBER DATE BALANCE IS DUE PERIODIC PAYMENT AND AMOUNT LIABILITIES plaintiff lists all liabilities of either or both spouses along with any person as of the date this action was commenced I ITEM NUMBER DESCRIPTION OF LIABILITY NAME OF ALL DEBTORS 5. 5. 5. 5. 5. 5. 5. 7. Teamsters Mastercard Belden Jewelers Sears Boscov's Beneficial Met-Ed Agway Energy Shirley Booher Husband and Wife Husband and Wife Husband and Wife Husband and Wife Husband and Wife Husband and Wife Husband and Wife Husband and Wife ITEM NUMBER DATE LIABILITY WAS INCURRED AMOUNT OF LIABILITY ON DATE INCURRED & ACTION WAS COMMENCED 5. 5. 5. 5. 5. 5. 5. 7. During marriage During marriage During marriage During marriage During marriage During marriage During marriage During marriage $4,000.00 350.00 1,314.97 250.00 756.22 234.63 296.59 1,500.00 ITEM NUMBER DATE BALANCE IS DUE PERIODIC PAYMENT AND AMOUNT -.. "I [1' I r .~ (..'~ , " ~I( 't " 1'1.. .. , II.. rl)1 r;': "I I " r .. [, . (' I,' \..~ I' r, l , U' e) >,' ..cd ~ frtc ,~g =' i2 ci\E8 ::Em~..:v;i Qd e d ~~ ..coOli~E' b.O ~ F 'ij Co =' Z ,l::l: o '"Ill o ~ ~ other Income: Weekly Monthly Yearly (Fill in Appropriate Column) Interest Dividends Pension Annuity Sooial Security Rents Royalties Expense Account Gifts Unemployment Compo Workmen's compo Total $ $ $ TOTAL INCOME $ BXPENSBS Weekly Monthly Yearly (Fill in Appropriate Column) Home Mortgage/Rent S500.00 Maintenance 50.00 Refuse Removal 24.00 Electric 75.00 Coal Oil 110.00 Telephone Water 80.00 Sewer Employment Public Transportation Lunch 125.00 Taxes Real Estate Personal property Income 250.00 Insurance Homeowners Automobile 682.00 Weekly Monthly Yearly (Fill in Appropriate Column) Personal Clothing Food Barber/hairdresser Credit payments Credit card 250.00 ]00.00 20.00 100.00 200.00 Charge account Memberships Laundry Dry cleaning 10.00 Loans Credit Union ]50.00 PHEAA PHFA Miscellaneous Household help Child care Papers/books/ magazines Entertainment 20.00 ]50.00 150.00 Pay TV Vacation 38.95 1. 500.00 " ". Legal fees Charitable contributions Weekly Monthly Yearly (Fill in Appropriate Column) 600.00 100.00 other child support Alimony payments other TOTAL BXPBNSBS (I 110.00 2.132.95 4.512.00 INSURANCB Coverage. Teamsters Health and Welfare Policy company No. H W C Hospital Blue Cross Other Health 275-78- ..1L ..1L Assurance 434300 Medical Blue Shield other Health 275-78- ..1L ..1L Assurance 434300 Health/Accident Disability Income Dental Health 275-7B- ..1L ..1L Assurance 434300 Other - - - HaHusband; WaWife; CaChild Joanne Harrison Clough ATTORNEY AND COUNSELOR AT LAW 845 Sir Thullhll ('<'url, Sullc l1A H.mi.burll. PA 17109 '('.I.ph..".: (71"1) 54005 lOt! F..., ("110') 540,'11'1'1 July 26, 1999 Prothonotary of Cumberland County Cumberland county Courthouse 1 Courthouse Square Carlislo, PA 17013 RBI DOOBBR V. BOOBSR NO. "-1847 Dear sir/Madam: Enclosed please find the original and three copies of Plaintiff's Amended Divorce Complaint and the original and four copies of Motion to Withdraw all Economic Claims. Would you please return the time stamped copies of the Amended Divorce Complaint to me in the enclosed self addressed stamped envelope. Once the Order to Withdraw All Economic Claims has been signed by the Judge, would you please return three copies to me and forward one copy to E. Robert Elicker, II, Esquire in the enclosed envelope. Thank you for your attention to these matters. Should you have any questions, please do not hesitate to contact me. sincerely, Joanne H. Clough JHC/kah Enclosures: Amended Divorce Complaint Motion to Withdraw Envelopes CCI Kirby F.. Booher (w/encl.) E. Robert Elicker, II, Esquire (w/encI.) MYERSTOWN OFFICE: 34'1 ~'..I ~t.'i" A,."..., My."t.."", I'A 17067. (717) 866,,11<16 Ily '\1'1"'1..111I.,,1 O"ly KIRBY E. BooIIBR, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA v. I NO. 1847 1996 I TINA L. BOOHER, I CIVIL ACTION - LAW Defendant I IN DIVORCE I 0110& 'ft) 1I%1fIIm1l". a'.lT.. .nnwnllTQ CLaTII. AND NOW, this day of , 1999 upon review of the attached Motion, it is hereby ORDERED and DECRBBD that all economic issues be withdrawn from this divorce action. BY THE COURT: ,J. KIRBY E. BOOHER, IN THE COURT OF COMMON PLEAS plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. . NO. 1847 1996 . TINA L. BOOHER, . CIVIL ACTION - LAW . Defendant . IN DIVORCE . : K~IOM ~ .X~RA. aLL BCONOMYO CLaTYR AND NOW, this ~day of , 1999 cODle. the Plaintiff, by and through his Joanne Harrison Clough, Esquire and respectfully avers as follows: 1. A Divorce Complaint in the above captioned matter was filed on April 8, 1996 with the Prothonotary of Cumberland County, pennsylvania. 2. On January 11, 1999, an Order to Include Equitable Distribution to the Divorce Complaint was signed by the Honorable Edward E. Guido. 3. Plaintiff, Kirby E. Booher now wishes to withdraw all economic issues concerning this divorce action. WHEREFORE, Plaintiff respectfully requests that all economic issues be withdrawn from this divorce action. KIRBY!. BOOHER, . IN Tn! COURT OF COMMON PLEAS . plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . I V. I NO. 1847 1996 . . TINA L. BOOHER, I CIVIL ACTION - LAW Defendant I IN DIVORCE VInI'l.:raa'l':ro. I, Kirby B. Booher, verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: 7-,2)~" Jt:J:IBY .. BOO.", I IH Ta. COURT 01' COIIIIO. PLIIU plaiDtiff I C1JJOIIJlLIUlD C01J1l'1'Y, P...8YLVUIA I V. I HO. 1841 UU I TID L. BOOJIBR, I CIVIL ACTIO. - LAW Derendant I IH DIVOllC. I CKR~%.%CATB O. BKRVICB AND NOW, this ~ day of #-, 1999, I, Katherine A. Hornyak, Secretary to Joanne H. Clough, Bsquire, Attorney for the Plaintiff, Kirby B. Booher, hereby certify that a copy of the within document has been served, by depositing a copy of the same in the United states mail, first class, postage prepaid, certified/ Restricted delivery at Harrisburg, Pennsylvania, to the following addressee: Tina L. Booher 28 Michelle Avenue, #28 Leesburg, FL 34748 By: _____lULtbx_~_~Qr________________._._____ Pllllntiff In !he Court of ClIInIIIlIn P1Cl11 of C&UDberfand CounlY, PC1lnr/"~ -..----..-.-..----------.---------------..---- VI. N". 96-1847 ......---.....---.-------- CIvil. 19.__.__ Tlnn I.. Booher -----.---------------------------------------- .----..-.--.---..-----.---.---.-------.------. Ilefendllnt IN IlIVORCI, --..-...--.----------------------------------- .---....... .--... . . ..... --.-----.-.----------- TO TilE OFFICE OF TilE PROl'Il0NO'l'AIlY: .--------.------------...-----...--------------------.--.----------.-.--.----.----------------.-. Pleaee withdrnw my appearance all counsel for Kirby E, Booher. Plaintiff In the nbave-captloned divorce net lon, lie Is preHently repreHented by .Jonnne ._ ._. '1- _..____._._______.___._.._________._. ... ..---..-....--..-. ...-. -...-.------..-.--------. .----..--..------.-----------.-....--------------------------.----....----..---..--....--.--. lIarrison Clough. Esqui re. " , I I. 1\ , ~ .---..----.--.--.-------..-.-.--------.------.-..---.-----------.-----------.---------.---------- .-----------.---------------...-.-..----------.---------------.---..-----..-------.-.---.-.-..-- .---------------------.-----......-------.-----...---.-.--...-..-.....---..----.-..-.----.-----.- ----.---------------------...---------.--------.--.-------...-.........-..-.--.-..--..-.-..----.-- To Lnwrence Welker Prolhonotary f! --------------------.--------------------- . -------------------------- 19_____ 1 /' ::;'-lA./1 /: Susan J. ~~~'~l:m;;;;(;;-pj.:i~ff.-..- I' p ; ! ~ I t i l r i' , cc. Lindsny Baird f I, , .:\;,1. '",,",> q ti :' j I' j. ~ ,. . I " . " . \f'l ", ~ ,,- \ I <, " ~.-,' , , roO \ 1 I : " " F p .:J" .:1 i'': .'. ~ '" ,.. ~~~f; .I~ ( . I, L.. I. i~. b e.\ u- '.; '.f 'J" -): ,~ ,:"j ',- "l.'J \ ~~. ",:,\\) ..Itl. .-\: ") V cr. ;'C ..... .,r - _______e_...____...._.....______...._.___ '~IV ...-.---------.-.------------.-.-.- ------61 .______w..__..___________._ pand 3dl03Vlld .._.-----~-----_.--.-------------------- 'SA ..---------------------------------------- -.-.--61 'tw'J. .-.----------.---- .oN , , .. ~l '. . \ -'Io-,t. , -' ','I " " ""f1 ',," t ; \ I' I: '. I 'i, " . .' '\. ,.' , I '(.~. .. .! f...r... . 1 I " , i , , \ . l I , I, It i, I ,\ , I I , l" 11 jI- I ...-.--.- ~ ..:I' ;-. ..:J t.... " B. <I, ,"7 .'..(. au.. :';;?' ~0 :-r. (.).j' ~{j CL. < ,;j .,'>: -", '(f? E' ",-, ;;.!; ff"~ f::1 r1fe (, u.. '.' ..: 13 ,... '::' C1'. 0 >.~ < ,..c::: ...J::: e-~,~ 2; =Ilil oi!;:::s ~ !~~ Cl'd i~~ ~j~lE o ell) o ~~ ..., ..... A""", ~ -. Joanne Harrison Clough ^,jlIRNIlY "1:UUNSI~.oR ^T lAW 84' Sir Thorn.. Courl, Sulle II ^ lIarri.burg,.J'A 1710') (717)'40,'100 JUL '; U U:J9tb , plaintiff I IN THE COURT 0 CUMBERLAND COUNTY, PENNSYLVANIA NO. 1847 1996 . . v. TINA L. BOOHER, Detendant I I CIVIL ACTION - LAW IN DIVORCE . . ORDIIR '1'0 WITHDRAW ALL IICOHOIIIC CL"IIIS AND NOW, this 30 ;tJ.. day of ~''a , 1999 upon review of the attached Motion, it is hereby ORDERED and DECREED that all economic issues be withdrawn from this divorce action. BY THE COURT: ..J..~I 6}lw1lA<l c.)i~ ,J. KIRBY E. BOOHER, IN THE COURT OF COMMON PLEAS plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . v. NO. 1847 1996 . . TINA L. BOOHER, CIVIL ACTION - LAW Defendant IN DIVORCE . . KOTXON TO WXTHDRAW ALL BCONONXC CLAXMS AND NOW, this ~ day of , 1999 comes the plaintiff, by and through his Harrison Clough, Esquire and respectfully avers as follows: 1. A Divorce complaint in the above captioned matter was filed on April 8, 1996 with the Prothonotary of cumberland county, pennsylvania. 2. On January 11, 1999, an Order to Include Equitable Distribution to the Divorce Complaint was signed by the Honorable Edward E. Guido. 3. plaintiff, Kirby E. Booher now wishes to withdraw all economic iasues conoerning this divorce action. WHEREFORE, Plaintiff respectfully requests that all economic issues be withdrawn from this divorce action. Respectfully submitted . v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 1847 1996 CIVIL ACTION - LAW IN DIVORCE KIRBY E. BOOHER, plaintiff TINA L. BOOHER, Defendant VBJlx.xcaTION I, Kirby E. Booher, verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities. Dated I 7-..;:o-7? KIRBY I. BooBIR, I IN TBI COURT or COKKON PLIAB Plaintiff I CUHBIlRLMfD COURTY, PBNNSYLVUIA I v. I NO. 1847 11196 I TIHA L. BooBD, I CIVIL ACTION - LAW Defendant I IN DIVORCB I CBRTIrIC.TB or SERVICB AND NOW, this .dJJ!:.. day of #-, 1999, I, Katherine A. Hornyak, Secretary to Joanne H. Clough, Esquire, Attorney for the Plaintiff, Kirby E. Booher, hereby certify that a copy of the within document has been served, by depositing a copy of the same in the United states mail, first class, postage prepaid, certifiedl Restrioted delivery at Harrisburg, Pennsylvania, to the following addressee: Tina L. Booher 28 Michelle Avenue, #28 Leesburg, FL 34748 By: -.' KIRBY E. BOOHER Plaintiff IN TIlE COURT OF COMMON PI,EAS OF CUMBERLAND COUNTY. PENNSYINANIA CIVI I, AC'rION - I,AW vs. TINA L. BOOHER Defendant NO. 96 - 1847 CIVIl, 19 IN DIVORCE STATUS SHEET DATE: 12/8/98 ACTIVITIES: for pretrial statementsl no economic claims / ".. ~ -, -- ~ (-1; /1 J OFFICE OF DIVORCE MASTER CUM8ERLANO COUNTY COURT OF COMMON PLEAS 9 North Hanovor Slrool Carllslo, PA 17013 (717) 240.6535 E. Robert Elicker, II Divorce Maolor Treel Jo Collier Otllco Manege/tRopaner Welt Shore 697,0371 Ex!. 6535 January 14, 1999 Lindsay D. Baird Attorney at Law 37 South Hanover street Carlisle, PA 17013 Joanne H. Clough Attorney at Law CLOUGH & MURPHY 845 Sir Thomas Court, suite l1A Harrisburg, PA 17109 REI Kirby E. Booher vs. Tina L. Booher No. 96 - 1847 civil In Divorce Dear Ms. Clough and Ms. Baird: I am in receipt of an order of Court dated January 11, 1999, allowing the Plaintiff to raise the claim of equitable distribution. Now that an economic claim has been raised, I am directing that pre-trial statements be filed in accordance with P.R.C.P. 1920.33(b) on or before Monday, February 1, 1999. 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 NOTEI 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.