The URL can be used to link to this page

Home My WebLink About96-02293 "'1 , ..- 5. Date plaintiff's Waiver of Notice in S3301(C) Divorce , . was filed with the prothonotary: May 9, 1997. I. . i I Date defendant's waiver of Notice in S3301(C) Divorce was filed with the prothonotary: May 9, 1997, I, Date II - 'I" ~ 7 r-~- ..-.- Michael Levinson Certi ied Legal Intern til ~. ya,..! Jt" ..,.,,} t..~,,-U/\ OMAS M, ACE OBERT E, INS KATHERINE C. PEARSON Supervising Attorney GAIL R. SHEARER FAMILY LAW CLINIC 45 North pitt Street Carlisle, PA 17013 717/243-2968 CHANDRA ROTH, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE ALAN E, ROTH, Defendant NO, 96 -2293 CIVIL TERM CIRTIPICATI OP SERVICE I, Michael Levinson, Certified Legal Intern, The Family Law Clinic, hereby certify that I am serving a true and correct copy of a Praecipe to Transmit Record, plaintiff's and defendant's Affidavits of Consent, and plaintiff's and defendant's Waivers of Notice to Murrel R, Walters, Esq., counsel for the defendant, at his office located at 54 East Main Street, Mechanicsburg, pennsyl vania 17055, by first class Uni ted States mail, postage prepaid, the 9th day of May, 1997. --=~ Michael Levi~s;n Certified Legal Intern , '.,' FAMILY I,AW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3f39 ,I', , , I . I , " 1\ I, I, , I. '. I, \ (1 ..n n (' _J ." :l: .., -,- ,0,,, I _~ p':ll .,( 1 If' ~':l , ':~ i/~ : <.0 1 ) .< ,- I" '. .' ~. ;.-1 :r:, :,1;': ( ," .j~~ ,J."t , " ",I :1;- ~, ,! -~) ~'i! '". en ,I I , ',I , , I' I I [ ! . t I t ~ ' .: ~ I " , l :\ CHANDRA L, ROTH. Plaintiff : IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ! I , I! v, : CIVIL ACTION - LAW : IN DIVORCE ALAN E. ROTH, Defendant : NO, <)6. :J.J'lJ CIVIL TERM I I i I I NOTICf: TO I>EFENI> ANI> CLAIM RIGHTS You have heen 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 III do so, the case may proceed without you and a decree of divorce or annulment may he entered against you hy the court. A judgmelllmay also he elllered against you for any other claim or relief requested in these papers hy 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 divorcc is indignitics or irretrievahle hreakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumherland County Courthouse, Carlisle, 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 MA Y LOSE TIlE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumherland County is required by law to comply with the Americans with Disahilities Act of 1990, For information about accessible facilities and reasonahle accommodations availahle to disahled individuals having business before the court. please contact our office. All arrangements must be made at least 72 hours prior to any hearing or husiness hcfore the court. You must allend the scheduled conference or hearing. Court Administrator Cumherland County Courthouse Carlisle. PA 17013 717/240-6200 CHANDRA L, ROTH, Plaintiff : IN TilE COURT OF COMMON Pl.EAS OF : CUMBERLAND COUNTY . PENNSYLVANIA v. : CIVIL ACTION - I.A W : IN DIVORCE ALAN E, ROTH. Defendant : NO. 96- CIVIL TERM i. ~ERTlJo'ICATE (W SERVICE I, Stephen Metz, Student Allorney. Family Law Clink;, herehy certify that I am serving II true and correct copy of Plaintiff's Complaint for Divorce on Alan E. Roth, residing at 30 Bethel Church Road. Dillsburg. York County, Pennsylvania. hy depositing a copy of the same in the United States mail, certified. restricted delivery. return receipt requested. postage prepaid. thisJ~llh day of PV'; \ . 1996. ; Jje;frkuc M~ Stephe Metz Student Allorney THE FAMILY LAW CLINIC 45 North Pill Street Carlisle. PA 17013 (717) 243-2968 ~. - ,- - 0 ! ';1 C ) -" ) .' I 1 ~ -- ") .. III -. ,; ~'" <., ! 0 C 'J ,: ! , .' . I ~. i ~~f ;1,.1 -'.: '. I'" . ' ',:1 ~; .0 sri -I -c'lll' :l": "j ~.).. ;~~ 0)' .-<: '~171...1'i.' " ' '1 C:~.1.. ..0' "~ ~ ~, 'l~ ....-... > ;:-":r ~"': ~r';. \. ::.i' ~"" ( .. ;. ,,..:) " --. ~ .~ ,1.",.., ,'; " ;.1.. I' , , n ..0 ? r:~: . .... ",ii ~:r. .,.J :.... OJ'" .-< ':~i r'.. I /\ (I} ,: '.0 J" ." , 1;,.': ~ , ,I ~ '. ;'(;r :.:r;; ;~ ,;"r - .. ;..., .- '.J ~". .. -, " :~1 ,~) ~2 ~ . . ", , . " n v:l 9. ~N~J -J ;T- .,1 "n('. 'I I~',. ,11 C}j'.,\ -< ","I ~.. ., , 'I' " 1;\ '0 .) "' J. r~: (' ".. '), - ~ir. "'-':" , ., - '1 ~ 't .- '1 )... ~: ,. .', ;'.',4 :,,) ~1:f .~ .... " , , Social sccurity bcncfits: 0 Support paymcnts: $50 Child Support Pass Through Disability paymcnts: 0 Uncmploymcnt compcnsation and supplcmcntal bcncfits: 0 Worknllll1's cllmpcnsallon: 0 Public Assistance: $403 Fuud Stamps: $279 (d) Other contributions to household support (Wifc)(I-lusband) Namc: If your (wife)(husband) is cmploycd. SUIlC Employcr: Salary or wages per month: 0 Type of work: Contributions from childrcn: 0 Contributions from parcnts: 0 Other contributions: 0 (e) Property owned Cash: Checking account: $3 Savings account: $5 Certificates of dcposit: 0 Real estate (including home): 0 Motor vehicle: Make -- Chevrolet: Year -- 1988 Cost: $500. Amount Owed: $0 Stocks; bonds: 0 Other: 0 (I) Debts and obligations Mortgage: 0 Rent: $18 for HUD assisted housing Electric: $95 Phone: $104 Food: $250 Diapers/toiletries: $80 Book Club: $20 Gasoline: $25 Personal Service Loan: $20 Auto Pass (Credit Card-Auto: $20 Sears Charge: $10 Fast Food: $20 Entertainment: $32 Car Insurance: $43 ~ , ' ! '.; , " -.. -~I " J , , , , J "J' C. , 1 '~-) , ", :,) 'r~) r' -- r'n .. .. .... ! -', ._1,'1, ALAN E. RO'rH, petitioner IN THE COURT OF COMMON PLEAS OF I CUMBERI~ND COUNTY, PENNSYLVANIA I vs, 96 - 2293 CIVIL TERM : CHILD CUSTODY CHANDRA ROTH, Respondent . . ORDl'lR or COURT 'J day of 11., I?' AND NOW, this l ' ' 1997, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before 0,._, { <'wi", , ,'I,q the conciliator, at I . '::{9 W ;/) ,> ,I 1 f. f1 """ ': bt i" on the ..) day of Arc \\ 1997, at 1:(j.: \,~,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. Either party may bring the child who is the subject of this custody action to the conference, but the child/children's attendance is not mandatory. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, j/~ft j $.vL, ~, ( ~~ J custody conciliat~:7' / VI f By: YOU SHOULD TAlI THIS PAPER TO YOUR LAWYl'lR AT O.C.. I' YOU DO MOT HAVl'l A LAWYIlR OR cANNOT AFI'ORD 01111, GO TO OR T.L.PROM. U. O"ICa Sl'lT FORTH BilLOW TO rIND OUT ..IRIl YOU CAM G.T L.GAL BaLP. office of the Court Administrator cumberland county courthouse Fourth Floor carlisle, PA 17013 (717) 240-6200 'i ! 'J I'i , ' ALAN E. ROTH, Pet! t!oner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, 96 ~ 2293 CIVIL TERM CHANDRA ROTH, CHILD CUSTODY Respondent COMPLAINT .OR CUSTODY .. AND NOW, this /' ~ I"day of I,' ...I ."> . . .;'4L "'/...c( ,Y , 1997, Plaintiff, ALAN E. ROTH, by and through his attorney, MURREL R, WALTERS, III, ESQUIRE, files this Petition for Custody and avers as follows: 1, Petitioner, the defendant in this pending divorce action, is Alan E. Roth, an adult individual who currently resides at 102 S, Baltimore street, Apt. #5, Dillsburg, York County, p.mnsylvania. 2, Respondent, plaintiff in the divorce matter, is Chandra Roth, an adult individual who currently resides at 271 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania, 3, Petitioner and respondent are the parents of two children: Andrea Nicole Roth, born April 19, 1993, and Aiden Nathaniel Roth, born June 10, 1994, 4, Both children have resided with respondent since their birth. 5, The children are the natural children of both petitioner and respondent and were born during their marriage, 6. Respondent filed a divorce action in April 1996 to No. 96- 2293. _, VIRIrICATIOIf I verify that the statements made in the foregoing Complaint are true and correct, I understand that false statements therein are made subject to the penalties of 18 Pa, C,S, S 4904, relating to unsworn falsification to authorities, , , ";I , ' I " \", I 11,1," , i',;; 'Jt'\', \ I L' ,'0, " ", , " , d\ " . " , ' ALAN E. ROTH, I IN THE COURT OF COMMON PLEAS OF Petitioner I CUMBERLAND COUNTY, PENNSYLVANIA I ve. I 96 - 2293 CIVIL TERM I CHANDRA ROTH, I CHILD CUSTODY Respondent CIIRTIJ'ICATII OJ' 811RVICIl I hereby certify that I am this day serving a copy of the foregoing document upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of civil Procedure, by depositing a copy of same in the United States mail, Mechanicsburg, Pennsylvania, first-class, postage prepaid, as follows: Tina Moukoulis Student Attorney Family Law Clinic 45 N. pitt street Carlisle, PA 17013-2943 and Chandra Roth 271 Plaza Drive /' .oil'~ So' in.. , o~:{( t41( I. . Murrel R. Walters, III, Esq, Attorney for Petitioner 54 East Main street Mechanicsburg, PA 17055 (717) 697-4650 J.D. No, 24849 February 25, 1997 I" , ~ 'it- '- ~ i~ :J-- ~ ~ ~ \ II '- . ~ ~ i.l: ~ i"~ t,'~ ",11 .,' : .~ (). .. . n.' .' ... I. ~ . , <)1 .., ~ I' ..:, [;;: '-1 ~ ". . C_t ( il) "" I.J 'fl. I L.. I' r- ) '-) O' ; .) f:;;S cn~ ;5 ~ ):' ..:I>'iX ll<cn~ z~f-< O~~..:I ll<H ::-- 8~-t; ~. c o ~ f-lU C1 ~o ~ cz......cn U":O'oP ..:INU ~~N :t:~ c: f-l~'..:I z~-oti H 0'0 . ~ ~ . Ul :> . :t: f-l o ~ :>< o o .... Ul :::> u P<: o ~ ~ H j ~ - o u " Il ~ ~ ~ 8 :! ~ ~ E ~ ~ ~ z i ;>~~~ ~ ~ ~ ~ w he ~ ~ :J u ~ ~ ~ QI t: o ,~ ., ,~ ., QI p.. ., ~ "C C o c Ul <Il ~ = - . ~ ~ c: ~ U 3 ..: .'... ,. il\ . ,'to ~ ~ :(. ~ t fr. <::1 ~ l.J ..:~; C'>J ' -, 1I,CI '. I ~. I:l- (J' . OJ .- .' " l ., :,:p .' '-, " '-r' ; , - ""., '. ~"" t. ~..'I ,I, Cl ,. ,.,) .j!. c,...... ,] :'b' fo!' " . ':'1;'; .; [... '"' )l,:j " L>_ ~ (.100 '-' ,... _J (1' I..) " " ~ II -' ~ v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACfION - LAW IN DIVORCE CHANDRA Rom Plaintiff ALAN E, ROm Defendant NO, 96-2293 CIVIL TERM PETITION FOR LEAVE TO WITHDRAW PURSUANT TO RULE 1.16(b){.5l AND (61 OF mE PENNSYLVANIA RULES OF PROFESSIONAL CONDUCT Petitioner, The Family Law Clinic, hereby petitions to withdraw from further representation of Chandra Roth, pursuant to Rule 1,16(b) (5) and (6) of the Pennsylvania Rules of Professional Conduct, and in support therefore avers the following: 1. The Family Law Clinic agreed to represent Ms, Roth in March 1996, 2. On April 29, 1996, The Family Law Clinic filed an IFP and Complaint in Divorc:e (03301(c) and 03301(d)) on behalf of Ms. Roth, 3. In September 1996, the issue of custody was raised by the defendant, Mr. Roth. 4. The Family Law Clinic has been attempting to negotiate with Murrel R. Wallen, Esq., attorney for the defendant, with regard to these custody and divorc:e matten. 5, During the course of this representation, irreconcilible differences have "left between The Family Law Clinic and Ms. Roth which have made further repraenlllion ofber unreasonably difficult. v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE CHANDRA Rom, Plaintiff ALAN E. ROm, Defendant . . : NO. 96-2293 CIVIL TERM CERTIFICATE OF SERVICE I, Tina Moukoulis, Student Allomey, The Family Law Clinic, hereby certify that I am serving a true and concet copy of a Petition for Leave to Withdraw on the following persons by first class United States mail, postage prepaid, the a day of I ~ hI'Ll tit L/ , 1997: I Chandra Roth, residing at 271 Plaza Drive, Boiling Springs, Pennsylvania 17007, and Murrel R, Walters, Esq" at 54 East Main Street, Mechanicsburg, Pennsylvania 17055 (counsel for Alan , .,t Roth). 1 , /,i I , " " Ti a Moukoulis Student Attorney / 1ia.J I? d2/\.L~ ~ornas M. P~ obert E. Rai s Katherine C, Pearson SUPERVISING ATTORNEY Gail R. Shearer STAFF ATTORNEY ~ I,: FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 " , ("') \tJ 9, t' ..I '. . ill ., ;H" ;\ t' i':' t!-:I - ',t'l; ~. I.n ' , I r~..,' -n " :'1;0 /"' :.'Jl: ~,~ .. ,'?"i" ~ q :J* ~:.. ~ i:.. :.3 tJ1 ~t ,......' - .... - ." I I , , I 5. Specifically denied, By way of further answer, Re.pondent, Chandra Roth, speoifically denies that any irreconcilable differences have arisen between herself and The Family Law Clinic and Ms. Roth specifically requests that The Family Law Clinic continue in representing her interests until the matter pertaining to custody and divorce are resolved. Petitioner, Chandra Roth, further believes that her interests will be prejudiced and that she will suffer additional delay in resolution of the above captioned matter if The Family Law Clinic is permitted to withdraw as legal counsel at this juncture. WHEREFORE, your Respondent, Chandra Roth, respectfully requests this Honorable Court to deny petitioner's, The Family Law Clinic's, request for permission to withdraw as counsel for Ms. Roth in this matter and grant all such further relief as is just and proper, Respectfully submitted, Date: Februarv,'j( 1997 f/' ,j By: l ;(1If/1((t1,-, Chandra Roth 1< :'Z/1 'I,t" b' ~l ~- 2 -, . . CERTIFICATE OF SERVICE ..' I, Chandra Roth, do hereby certify that a true and correct oopy of the Reply to Petition to withdraw in the above-captioned matter was hand delivered on February :J!).., 1997, on the followingl Tina Moukoulis, student Attorney The Family Law Clinic 45 North pitt street Carlisle, PA 17013-2943 Respectfully submitted, Date: Februarv ,~1. 1997 By: (.ALA.,Hi/JiM ,/,I4dh Chandra Roth 3 " , (' ,n (', r~ -l ..,1' "'" I ~, r'I1 '''01 (, 'J 'Ii .. , ~ I" ",!j '., I ~" l' ~ ' ,.1 ; ), " ,i\ , ~ j ,. ) , ,!? "(II d' r.- ":.~ ." -<. CHANDRA ROTH, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ., V, ALAN E. ROTH, DEFENDANT 96.2293 CIVIL TERM 0130ER OF COURT AND NOW, this 11th day of March, 1997, based upon the petition of the Family Law Clinic to withdraw as counsel and the answer filed by Chandra Roth, a hearing on the Issua shall be conducted In Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania, at 4:00 p.m., Tuesday, April 1, 1997. Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Chandra Roth 271 Plu.8 Drive Boiling Springs, PA 17007 Murrel R. Walters, III, Esquire For Defendant :saa ~,'~ov..'4.>l'-'i\.J...4."\ l/j,)../'l'l, ~ "",~ . , , CHANDRA ROTH IN THE COURT OF COMMON I'l,EAS OF , P~aintif f CUMBERLAND COUNTY, PENNSYJ.,VANIA , I' , v. CIVIL ACTION - LAW ,. IN DIVORCE: ALAN ROTH . . I, , Defendant NO. 96-2293 CIVIL TERM ' II PRAICIPE TO WITHDRAW PETITION FOR LEAVE TO WITHDRAW AS COUNSEL TO THI PROTHONOTARY I Kindly withdraw the Petition to Withdraw as Counsel, filed February 14, 1997 by the Family Law Clinic, Date: March 7, 1997 Tomas M, lace Robert E. Rains Katherine C. Pearson SUPERVISING ATTORNEY Gail R. Shearer STAFF ATTORNEY FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717.1 243-2968 Fax: (717) 243-3639 " " , ' " " r" II) ') .. , r" ... " """11 ~ J , , l'n rl'~ ! ~ ,. r;: I ,.11 (',; .~l ;'\J :~) '-11 ' 'I "I, : r } ,- I'll , ,. I '. I ..' en ,; ., !' . . . ALAN E. ROrH, I IN THE COURT OF COMMON PLEAS OF Petitioner . CUMBERLAND COUNT\', PENNSYLVANIA . I vs. I NO, 96-2293 CIVIL TERM . . CHANDRA RCYrH, . CIVIL ACTION - LAW . Respondent IN CUSTODY C1UlI!R or OOORT AND tOI, this r:;( day of ,;1./1. A upon consideration of the attached Custody ~~i~n ordered and directed as follows: , 1997, Report, it is 1, The Mother, Chandra Roth, and the Father, Alan E. Roth, shall have shared legal custody of Andrea Nicole Roth, born April 19, 1993, and Aidan Nathaniel Roth, born June II, 1994, 2. The Mother shall have primary physical custody of the Children. 3, The Father shall have visitation/partial custody of the Children in accordance with the following schedule: A, During the week of April 7, 1997 for one period of one hour of supervised visitation at the Iielen stevens Center in Carlisle; B. During the week of April 14, 1997 for one period of one hour of supervised visitation at the Helen Stevens Center in Carlisle; C. During the week of April 21, 1997 for one period of two hours of supervised visitation at Kidz Zone on the Carlisle Pike in Mechanicsburg; D. During the week of April 28, 1997 for one period of two hours of supervised visitation at Kidz Zone on the Carlisle Pike in Mechanicsburg; E. During the eight week period from May 5, 1997 through the week of June 23, 1997, for one period of four hours of partial custody per week: F. Thereafter, for one period of overnight custody (24 hours) per week on a regular basis. 4. The specific times for periods of custody under the foregoing provision shall be arranged by mutual agreement of the parties in such a way as to accOllll1Odate the Father's work schedule without interfering with the Mother's class schedule or daycare requirements. 5. The Father shall be responsible to pay all coets lUIIlOCiateCI ~~~ I I I , I p.;~~ ~ I ~ ... I ~ ~ !'~'J w~ i_O~1 1 - ~ - ... j,=,J/-: ... - , 'Ii,.. .~": ... . t'$ ~ a! ~ ~ ~ -Ii t. ~ f , . II ;1 Jl i ~ ~- ~ ~ - = ~ iiii r.;l"; ill:x ~ . . I to:! ~ I ~ ~ I I . . ~, . " . ';, ".' ,