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HomeMy WebLinkAbout02-4936 HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243.6090 ATTORNEY FOR PLAINTIFF Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. : CIVIL ACTION - LAW : NO. 02. .l.J91L CIVIL TERM BARBARA A. WILLIAMS, Defendant : IN DIVORCE NOTICE 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 in 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, 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 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, Pennsylvania 17013 717-243-3166 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. : CIVIL ACTION. LAW : NO. 02 - -'I9'J.~ CIVIL TERM BARBARA A. WILLIAMS, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301~ OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Eddie Williams, an adult individual residing at 20 Jane Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Barbara A. Williams, an adult individual residing at 20 Jane Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on June 7, 1980, in Carlisle, Cumberland County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. October ..lll....-, 2002 Lu,~ {~t~..;. EDDIE WILL AMS, Plaintiff HAROLD S. IRWIN, II Attorney for Plainti 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court 10 No. 29920 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. : CIVIL ACTION. LAW : NO. 02 . CIVIL TERM BARBARA A. WILLIAMS, Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. e.s. Section 4904 relating to unsworn falsification to authorities. October ..Jfl., 2002 IlL, e~Ii,,;; EDDIE WI L1AMS, Plaintiff ~~~ F Xi' '\) " ,V) _ r- "> 5> t c -l:: - ~ ~ ~ f.J () ,-- ~ [:1 '.';~, QJ/:-: ~"..; , -r_-'~ .- S-Si ~, ~;~~,' :::;:C" $C:(~:' '( , !3J a r\S c.::> '-' -, -- ':':\ -- .. .'\,) ~-d Co :0 -< () r, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. : CIVIL ACTION - LAW : NO. 02 - 4936 CIVIL TERM BARBARA A. WILLIAMS, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 {!ill1illl NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1 . That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about November 19, 2002, by certified mail "restricted delivery", addressed to the defendant at 20 Jane Lane, Carlisle, Pennsylvania 17013, return receipt No. 7001 2510 0000 3071 4575. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to uthorities. January 8, 2003 Harold S. Irwin, III Attorney for plainti SE!,I)! H (r,71'/ I T! rill' ',[' ',()I, . Complete ltem,1.2. .nu 3. AI8O,ocomplete item 4 if Re8triCted Delivery Is desired. ~ Print your name and address on the reverse so that we can return the card to you. Attach this card to the back of the mailpiece, or on the front if space permits. I 1. Article Addressed to: 1 iARt~JH~~ q. "'" l.\..\ f\MS 1.0 $\ro~ lJ\l\:>\a C~Q."\~\"\i, m \~13 3. Service Type XCertIfied Mail 0 Express Mail o Registered )(Retum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ~es ttS~ 2. Article Number t1 \" r 10 i/I\NV\ 30'" I (Transfer from servieelsbel) ,00 A.:) V""'-'V l PS Form 3811, August 2001 Domestic Return Receipt 102595-01 -M-ooa1 LI1 ['- LI1 ::r u.s. postal Service ~ CERTIFIED MA,IL REG;..JPT (DomestIc Mal' Only; No Insurance Coverage provided) ~ ['- CI rn CI CI C) C) postage Certified Fee postmark Here Return Receipt Fee (Endorsement Required) RElstricted Delivery, Fee (Endorsement ReqUired) , lOtal postage & Fees L $ C) ~ ~ ~:'~.1~~~~gB____~-,---_~-~~e"S------------------------"--' ~ ~::~. ::':00.. 2D .J ~ ~-----------.,,----------------- ~ -CiiY:siaie:ZI1;r--------------n-~u;---.n--.- \ 0 o c ~ ." (iI ~,~ ~;; ..,"" ,.:,. ~ i I r::- 0) CJ W '- ::t:oo .;e I \0 o "II -'-1 T FriifJ -om -,.., r-, ( f ) } !ZJk' ifJ ~~5 , In the Court of Common Pleas of Cumberland County, Pennsylvania fbrj~ (is' w~s O~M{) ~ ~ oif~~ ()Vt- ~cU{ V) (c)aA&aJtA /))~ U b > No. o:J - Lf q 3b Civil. 19 To Prothonotary 19 ~ /pc: ,>ill:', -'",\f- ,.. 0''''1 F'"'' I U~. illui LD CO." \':lj 3.: 2D .....':..J,!TY ", , No, Filed YS. PRAECIPE Term, 19 _ 19 , Atty. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Eddie Williams, CIVIL ACTION - LAW Plaintiff No. 02-4936 CIVIL TERM vs. Barbara A. Williams, IN DIVORCE Defendant PETITION TO WITHDRAW APPEARANCE TO THE HONORABLE JUDGES OF SAID COURT: The Petition to Withdraw Appearance of Linda C. Taliaferro, Esquire, attorney of Taliaferro & Associates respectfully represents: 1. Petitioner is Linda C. Taliaferro, attorney at Taliaferro & Associates. 2. Respondent is Barbara A. Williams, who resides at 20 Jane Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. A Complaint for Divorce was filed with this Honorable Court on October 10, 2002, thereby instituting the above-captioned divorce action. 4. Petitioner was retained by Respondent, Barbara A. Williams on February 5, 2004, to represent her in this domestic relations matter. 5. Petitioner asks to withdraw her appearance as Counsel for Respondent because, inter alia: a. There is a failure in communication between Petitioner and Respondent such that Respondent has not responded to Petitioner's timely requests for information and direction. b. Petitioner made an oral request of February 24,2004, and sent Respondent a letter by Certified Mail as well as United States First Class Mail on March 1, 2004, requesting that Petitioner be informed as to the status of Respondent's efforts to arrange her affairs so as to accomplish agreed upon goals. The letter is not attached as it (;ontains attorney-client privileged information, however it can be made available to the Court upon request. c. Petitioner has attached the USPS Returned Receipt (Exhibit "A") which indicated Respondent's acknowledged receipt on March 3, 2004 of Petitioner's letter of March 1,2004. d. Petitioner's March 1,2004 letter also informed Respondent that failure to communicate with Petitioner on or before March 10, 2004 would result in Petitioner's proceeding to withdraw her appearance as Counsel. e. Absent timely and open communication between Petitioner and Respondent, the Petitioner carmot adequately and effectively represent the Respondent in putting forth an agreed upon legal strategy on her behalf in the above- captioned divorce proceeding. f. The continued representation by Petitioner of Respondent would result in an undue financial burden on the Petitioner. WHEREFORE, Petitioner respectfully requests that her appearance be withdrawn for Respondent and that she be removed from the docket as Respondent's attorney of record. Respectfully Submitted, TALIAFERRO & ASSOCIATES Date: March 12,2004 By: EXHIBIT A . Complete ttems 1, 2, and 3. Also complete , Item 4 If Restricted Delivery Is desired. . Print your nemeand addlBSS,on the reveIll8 so that we can return the card to you, . Attach this card to the back of the mailplece, at on the front If space permits. 1. ArtIcleAdd~dto: fI1 f5 ~~ Wd1(a 2e llV~ S-fMJd od~5~t r; n()(3 3. ErvlC8 Type , - Mall C Express Mall Registered D Rllfum R8C$1pt fOr Men:handlse C Insured Mall C C.O.D. 4. Restricted Delivery? (E>tnl Fee) 0 Ves 2. ArtIcJe Number ~~~m"M 7003 1010 0001 2162 3843 PS Form 3811. August 2001 DomosUc RolUm Receipt 2ACPIlJ.OO.I4081 111111 FIrst-Oass MeII ~& Fees PeId Permtt No. Go10 UNITED STAlES POSTAL SERVICE · Sender: Plei!se print your name, address, and ZIP+4 In this box . L/~((;~'Q-l~~~ P O~ /1;y-'f} <;~ 2 ~ " tJ-a:v~h~ I e~ (7)~ ~ ""'.,'- '" \ 1...Jllflrh.,UU;..IM'.'I,.I;.I,I;;;l,l, U"fI/.I,l/fllI...' VERIFICATION Linda C. Taliaferro, Esquire, verifies that the statements made in the foregoing Petition are true and correct to the best of her knowledge, information and belief. The undersigned understands that the statements made therein are made subject to the penalties of 18 Pa. C. S. 9 4904 relating to unsworn falsification to authorities. A copy of the foregoing Petition was sent today to Plaintiff by certified mail, return receipt requested, address only. l. ~ Linda C. Taliaferro, Esquire Date: March 12,2004 CERTIFICATE OF SERVICE I, hereby certify that I have on this 12th day of March 2004, served a copy of the within PETITION TO WITHDRAW APPEARANCE on the person(s) named below by depositing a copy thereof in the United States mail, first class, postage pre-paid, addressed to the following; I~~ro(& g.Jrwlnl (II b<? '3 -; ~ as;t l-fs, 6lA SJ. Q.o.r--ks ~ 1 tA IJ 0 \ 3 ~RS. &A-i2~i(hG,q i!. Wi(l..lr:h11S ()i!> Jell-<.R. s: T ~ll<z,k, fA non By: LC1. I 1 da C. Taliaferro, Esquire 2 Verbeke Street Harrisburg, PA 17102 (717) 238-7670 LD.#: o ~~: ..c':__ -;i -, ~:;; = -,,- (':.1 '-01 ~ ::7 -Ci fllp:; -r:J;-TJ ~'''IC", ~~~ ~? --.- " ""'-c' ~n ,:;,:f;-"; ):-,'" ::;;:; N 1>:" en cr. -"'.~ EDDIE WILLIAMS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW BARBARA A. WILLIAMS, Defendant NO. 02-4936 CIVIL TERM ORDER OF COURT AND NOW, this 26th day of March, 2004, upon consideration of the Petition To Withdraw Appearance, a Rule is hereby issued upon Plaintiff and Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 10 days of service. BY THE COURT, Linda C. Taliaferro, Esq. 220 Verbeke Street Harrisburg, PA 17102 Attorney for Plaintiff J. Harold S. Irwin, III, Esq. 64 South Pitt Street Carlisle, PA 17013 Attorney for Defendant Lo-jV-u ~<L<--d 3. .Jf,- () '-I ~. Mrs. Barbara A. Williarns 20 Jane Lane Carlisle, PA 17013 Plaintiff :rc \lINVS\X2,1;<\t .j'?,d t 't 'n~r ('t ,"" """1"0"1 /\.1. ~~ i'-jJ _.'. .,') ~~'.~:::<,'d' 'rl \'v 82 IG \old 92 B~" ~IlIlZ ,\\17 j.O~iO\1.l0\;jd 3\11 :lO 38\:1:\0-0311:l EDDIE WILLIAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW BARBARA A. WILLIAMS, Defendant NO. 02-4936 CIVIL TERM MOTION TO MAKE RULE ABSOLUTE TO THE HONORABLE JUDGE J. WESLEY OLER, JR, OF SAID COURT: BY THIS Motion to Make Rule Absolute, Linda C. Taliaferro, Esquire attorney of Taliaferro & Associates respectfully represents that: 1. On March 12, 2004, Linda C. Taliaferro, Esquire, a,ttorney of Taliaferro & Associates petitioned said Court to withdraw her appearance as counsel in the above civil action for Divorce. 2. On March 26,2004, this Court upon consideration of the Petition to Withdraw Appearance issued a Rule upon Plaintiff and Deftmdant to show cause why the relief requested should not be granted, 3. The Rule was made returnable within 10 days of service. 4, The specified time period has elapsed. 5, There is no objection from the Plaintiff or Defendant to the Rule issued by the Court on the Petition to Withdraw Appearance as Defense Counsel. WHEREFORE, Attorney Taliaferro respectfully makt: this Motion and requests that an Order which allows her to Withdraw Appearance as Counsel fl)r the Defendant be entered by the Honorable Court, and that she be removed from the docket as Dc:fendant's attorney of record. Respectfully Submitted, TALIAFERRO & ASSOCIATES Date: April 16, 2004 < r-. By: t~ ().t~ Lin a C. Tali erro, E~ 220 Verbeke Street Harrisburg, P A 171102 (717) 238-7670 1. D, #: 26504 Linda C. Taliaferro, Esq. 220 Verbeke Street Harrisburg, PA 17102 Attorney for Defendant Harold S. Irwin, III, Esq. 64 South Pit Street Carlisle, PA 17013 Attorney for Plaintiff Mrs. Barbara A Williams 20 Jane Lane Carlisle, PA 17013 Defendant CERTIFICATE OF SERVICI!; I, Linda C. Taliaferro, Esquire, do hereby certify that on th~s date I served a true and correct copy of the foregoing MOTION TO MAKE RULE ABSOLUTE, by U S. First Class mail to the following: Harold S. Irwin, III, Esquire 64 South Pitt Street Carlisle, PA 17103 Attorney for Plaintiff Date: l.{. -I' - 0 i r;:;~AA . Taliaferro, q CERTIFICATE OF SERVIC1B; I, Linda C, Taliaferro, Esquire, do hereby certifY that on tll1is date I served a true and correct copy of the foregoing MOTION TO MAKE RULE ABSOLUTE, by u. S. First Class mail to the following: Mrs. Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 Defendant Date: 4-/6 -6lf #~r;~ Linda C. Taliaferro, Esq t APR 1 9 2004 tf EDDIE WILLIAMS, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -. LAW BARBARA A. WILLIAMS, Defendant NO. 02-4936 CIVlL TERM ORDER OF COURT AND NOW, this 1 ~bl~ of:~, 2004, the Motion to Make Rule Absolute is granted and Counsel for the Defense is allowed the relief requested in her March 12, 2004 Petition to Withdraw Appearance as Counsel of record.. Linda C. Taliaferro, Esq. 220 Verbeke Street Harrisburg, PA 17102 Attorney for Defendant Harold S. Irwin, III, Esq. 64 South Pit Street Carlisle, PA 17013 Attorney for Plaintiff Mrs. Barbara A Williams 20 Jane Lane Carlisle, PA 17013 Defendant BY THE COURT, , ~>-7~ oil J. 11~ Lf- d-. l-O~ JW; / / ~ ~~ ~~ -'w tt:FS ~ o c::> M :c a.. ~ -:;> h"" (,2 "--'",( D;:; ..~'" ",,::. :~1.~ ~~lJ LIJ ~'.::--f.L a l"- N a::: a.. ...: ...:r = ~ EDDIE WILLIAMS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION -. LAW BARBARA A. WILLIAMS, Defendant NO. 02-4936 CIV][I.. TERM MOTION TO MAKE RULE ABSOLUTE TO THE HONORABLE JUDGE J. WESLEY OLER, JR., OF SAID COURT: BY THIS Motion to Make Rule Absolute, Linda C Taliaferro, Esquire attorney of Taliaferro & Associates respectfully represents that: 1. On March 12, 2004, Linda C. Taliaferro, Esquire, attorney ofTaliaferro & Associates petitioned said Court to withdraw her appearance as counsel in the above civil action for Divorce. 2. On March 26, 2004, this Court upon consideration of the Petition to Withdraw Appearance issued a Rule upon Plaintiff and Defimdant to show cause why the relief requested should not be granted, 3. The Rule was made returnable within 10 days of service. 4, The specified time period has elapsed. 5. There is no objection from the Plaintiff or Defendant to the Rule issued by the Court on the Petition to Withdraw Appearance as Defense Counsel. WHEREFORE, Attorney Taliaferro respectfully makt: this Motion and requests that an Order which allows her to Withdraw Appearance as Counsel fi)r the Defendant be entered by the Honorable Court, and that she be removed from the docket as Defendant's attorney of record. Respectfully Submitted, TALIAFERRO&~ASSOCIATES Date: April 16, 2004 By: < ,~. Lin a C. Tali erro, E~ 220 Verbeke Street Harrisburg, PA 17102 (717) 238-7670 L D, #: 26504 Linda C. Taliaferro, Esq. 220 Verbeke Street Harrisburg, PA 17102 Attorney for Defendant Harold S, Irwin, III, Esq, 64 South Pit Street Carlisle, PA 17013 Attorney for Plaintiff Mrs. Barbara A. Williams 20 Jane Lane Carlisle, PA 17013 Defendant CERTIFICATE OF SERVlCJi; I, Linda C. Taliaferro, Esquire, do hereby certifY that on this date I served a true and correct copy of the foregoing MOTION TO MAKE RULE ABSOLU1:E, by u. S. First Class mail to the following: Harold S. Irwin, Ill, Esquire 64 South Pitt Street Carlisle, PA 17103 Attorney for Plaintiff Date: Lf-/,- Oi C7~w ,Taliaferro, q CERTIFICATE OF SERVIC:I!~ I, Linda C, Taliaferro, Esquire, do hereby certify that on tb~s date I served a true and correct copy of the foregoing MOTION TO MAKE RULE ABSOLU1E, by U. S, First Class mail to the following: Mrs. Barbara A Williams 20 Jane Lane Carlisle, PA 17013 Defendant Date: 4-/6-(Y-{- cf41.It~ n c~ /",,,") C~ (.;,::::J ~- o -Tl '--i il1?2 -t1rn :.',c;:; ~j(:;~ ~n -) ):n ~>; ;;,) C\ -rJ 1') .r:- CJ r_,. ':J ~-< HAROLD S. IRWIN, III, I!SQUIRE AnGRNEY ID NO. 291120 84 SOUTH PITT STUET CARLISLI! PA 17013 (717) 2A3-8OIIO AnGRNI!Y FOR PLAINTIFF Plaintiff I IN THE COURT OF COMMON PLIEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, . . v. I CIVIL ACTION. LAW I NO. 02 - 4936 CIVIL TERM BARBARA A. WILLIAMS, Defendant I IN DIVORCE NOTICE 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 in 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, 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 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 A.'isociation 32 South Bedford Street Carlisle, Pennsylvania 17013 717-243-3166 '. Plaintiff : IN THI! COURT OF COMMON PLI!AS OF : CUMBI!RLAND COUNTY, PI!NNSYLVANIA I!DDIE WILLIAMS, : v. : CIVIL ACTION - LAW = NO. 02. 4936 CIVIL TI!RM BARBARA A. WILLIAMS, Defendant = IN DIVORCI! AMENDED COMPLAINT IN DIVORCE UNDER SECTION 3301 (Dl OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this amended complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Eddie Williams, an adult individual residing at 20 Jane Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Barbara A. Williams, an adult individual residing at 20 Jane Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on June 7, 1980, in Carlisle, Cumberland County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(d), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken and that the parties hereto have lived separate and apart for a period of at least two years. The parties reside in the same home, but have lived separate and apart since at least November 19,2002, the date that service of the original divorce complaint was served upon defendant. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and cormct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. January ..2fL.. 2005 ~; IJh~ ~DDIE WILLIAMS, Plaintiff ~I' i.- ,/, ... .._.:~._" . ,..., 1/' c?U~}'F J "'<- L-,' HAROLD S. IRWIN, III Attorney for Plaintiffr i .',__....0. 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court 10 No. 29920 I!DDII! WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBI!RLAND COUNTY, PI!NNSYLVANIA v. : CIVIL ACTION. LAW : NO. 02. 4938 CIVIL TI!RM BARBARA A. WILLIAMS, Defendant . . : IN DIVORCI! NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301Cd} OF THE DIVORCE CODE 1. The parties to this action have lived separate and apart since at least November 19, 2002, the date defendant was served with the original divorce complaint. 2. The marriage is irretrievably broken. 3. J understand that I may lose rights concernin!~ alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. J 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. of 4904 relating to unsworn falsification to authorities" January 2:fL, 2005 Lu.. /dJh.'~ EDDIE WILLIAMS, Plaintiff \jii',j\;>'>:~ c'\,~ A~_N:iC.1"-: -..'~n:J C',.. .("\1 J\"t ,.j::J 'UI ti~' IS H'fr son f,I:l~;ll. --- PlaIntIff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. : CIVIL ACTION. LAW : NO. 02. 4938 CIVIL TERM BARBARA A. WILLIAMS, Defendant . . : IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301fd) OF THE 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 (Checlc (i), (ii) or (both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may iose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. 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. .2005 BARBARA A. WILLIAMS, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wIsh to make a claim for economIc relief, y.ou need not file this counteraffldavlt. II: c) <;:,? VI ",., r,~',:;, c~::, "-'~ ( ::::-'"" --,,""' -- o " :-;1 riip;J .'J ' ;'.1(;" ),J. It.) __1..' ::1, '~ri:? c) ?'.. -':'," PlaIntIff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. : CIVIL ACTION. LAW : NO. 02. 4936 C:IVIL TERM BARBARA A. WILLIAMS, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF AMENDED COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 a 1 i NOW, Harold S. Irwin, III, Esquire, being duly s.worn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the amended complaint in divorce was served upon the defendant on February 4, 2005, by certified mail, addressed to the defendant at 20 Jane Lane, Carlisle, PA 17013, return receipt No. 7003 3110 0004 57754375. 3. That a copy of the signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsifi tio to authorities. February 7, 2005 Harold S. Irwin, 11\ Attorney for plaintiff 64 South Pitt Street Carlisle, PA 1701:3 717-243-6090 Supreme Court ID No. 29920 ....J o Retum Reclept Fee (Endorsement Required) CJ Restricted Delivery Fee rl (Endorsement RequIred) r'l m U.S. Postal Service"" CERTIFIED MAIL~RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) ostage & Fees m o o ~ 2.~~ (I1onifer__~ PS.f'onn 3811,,~ ~~, 7003 3110 0004 .n"~'H <,- '. 5775 4375 , , ~'f "'1540 \ , \, \ {, ..-~-../ -=..-----J!i' ) ~ .--\ ." ....'f'"i ({\ r':,~ 'c..... \ ~CJ .'~o %0 ,?c, 3. ~I ) ~ .. PlaIntIff : IN THE COURT C)F COMMON PLI!AS OF : CUMBERLAND C:OUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. ; CIVIL ACTION. LAW : NO. 02. 4936 CIIVIL TERM BARBARA A. WILLIAMS, Defendant : IN DIVORCE COUNTER.AFFIDAVIT UNDER ISECTION 33011dl OF THE DIVORCE (~ODE 1, Check either (a) or (b): G) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Cheek (i), (ii) or (both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken, 2, Check either (a) or (b): (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. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party, If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. 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, , #1.JuJ0fl a a, IJ)-I~->>~ RBARA A. WILLIAMS, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, ~ need not file thIs counteraffldavit. d~/ /~OS ,2005 .,.," , \ l."C .- _...~ I'"~ ~ . - Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. : CIVIL ACTION - LAW BARBARA A. WILLIAMS, Defendant : NO. 02-4936 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I, Marylou Matas, Esquire acknowledge that on or about March 3, 2005, I received copies of Plaintiff's Interrogatories and Request for Production of Docwnents directed to Defendant, in the above captioned action and acknowledge that I am authorized to do so on behalf of Barbara A. Williams. Date: 3/10/05 , , /I ';L~~ ,a.J. -nl CL (0 Mary 1f GRIFFIE ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ",1 c, ---_._~ II EDDIE WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO.: 02 - 4936 CIVIL TERM BARBARA A. WILLIAMS, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRARCTPR TO WTTHnRA W APPRARANCF, TO THE PROTHONOTARY: Please withdraw the appearance of Harold S. Irwin, III, Esquire, in the above-captioned action as Marlin L. Markley, Esquire is entering his appearance on behalf of the Plaintiff. 011f( r/ Date: 1 . 0 Harold S. Irwin, III, Esquire 64 South Pitt Street Carlisle, Pennsylvania 17013 Tel. (717) 243-6090 PRARC1PF TO FNTF,R APPFARANCF, TO THE PROTHONOTARY: Please enter the appearance of Marlin L. Markley, Esquire, in the above-captioned action on behalf of the Plaintiff. Respectfully submitted, arlin . arkley, Esquire LawOm es of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 Date: I (J- /7-200 S I'i Ii ::.:: ~:l .~- c) ~{1 c:;. ~:," . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. NO. 02-4936 BARBARA A. WILLIAMS, Defendant CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Barbara A. Williams, Petitioner, moves the court to appoint a master with respect to the following claims: ( X ) Divorce () Annulment ( X ) Alimony ( X ) Alimony Pendente Lite ( X ) Distribution of Property (Equitable Distribution) () Support ( X ) Counsel Fees ( X ) Costs and Expenses and In support of the motion states: (1) Discovery is not complete as to the claim(s) for which the appointment of a master is requested. (2) The Defendant, Eddie Williams appeared in the action and is represented by counsel, Marlin Markley, Esq. (3) The statutory ground(s) for divorce is/are 93301 (c) and/or (d) (4) Delete the inapplicable paragraph(s). (a) The action is contested. (b) An agreement has been reached with respect to the following claims: NONE. (c) The action is contested with respect to the following claims: ALL. (5) The action does nol complex issues of law or fact. (6) The hearing Is expected to take: one day (7) Additional information, if any, relevant to the motion: Plaintiff filed a Notice of Intention to Request the Entry of a Decree in Divorce on or after April 30, 2006. Defendant files this Motion herein to preserve her economic rights. Defendant needs the following information from Plaintiff to proceed: 1. Plaintiff's 2005 Income Tax Return 2. Plaintiffs most recent pay stub 3 Complete answers with updates to Defendant's Requests for Production of Documents, served on Plaintiff's prior counsel on February 16, 2005. 4. Complete answers with updates to Defendant's Interrogatories, served on Plaintiff, through his prior counsel on February 16, 2005. Date: 4/2-7/00 J I Marylo 10 # 84919 26 W. High St. Carlisle, PA 17013 c ~"l , " EDDIE WILLIAMS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-4936 BARBARA A. WilLIAMS, : CIVIL ACTION - LAW Defendant : IN DIVORCE ORDER APPOINTING MASTER AND NOW, this yttJ dayof ~ Esquire. is appointed master with respect to the following cl s:,(Uy Cc ~r1in Markley, Esq. Attorney for Plaintiff ~rylou Matas, Esq. Attorney for Defendant ,2006, e ~ ft-t':h/A. ff .~. ' , ~ .~ ~,O/, O'J,O ~ :) j ! '--) SAIDIS, FlOWER & LINDSAY ATIOR.'TIS.AToIAW 26 West High Street Carlisle,I'A DDIE WilLIAMS, Plaintiff v. ARBARA A. WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4936 CIVIL ACTION - LAW IN DIVORCE NOTICE OU ARE HEREBY NOTIFIED to plead to the within New Matter and Counterclaim ithin twenty days after service of this Answer and New Matter. ated: +/ Z 1/ (.,- Respectfully subrnitted, SAlOIS, FLOWER & LINDSAY . l LVtA, (1- n [ /.zci) Ma Olji atas, Esquire Attorney . 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Defendant SAIDIS, FLOWER & LINDSAY ATIURNEYS.AHAW 26 West High Street Carlislc,PA .. EDDIE WILLIAMS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-4936 BARBARA A WILLIAMS, Defendant CIVIL ACTION - LAW IN DIVORCE PETITION FOR ECONOMIC RELIEF SUPPORT, ALIMONY PENDENTE LITE. ALIMONY, COUNSEL FEES AND COSTS AND NOW, comes the Petitioner, Barbara A Williams, by and through her counsel, Marylou Matas, Esquire and the Law Firm of Said is, Flower & Lindsay and Petitions this honorable court as follows: 1. The Plaintiff is Eddie Williams, an adult individual residing at 20 Jane Lane, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Barbara A. Williams, an adult individual residing at 20 Jane Lane, Carlisle, Cumberland County, Pennsylvania. 3. The parties hereto are Husband and Wife, having been joined in marriage on June 7,1980. 4. The parties separated on or about October 10, 2002. 5. Plaintiff filed a Complaint in Divorce on or about October 10, 2002, requesting a divorce based upon section 3301 (c) of the divorce code, alleging that the parties' marriage was irretrievably broken. 6. Plaintiff filed an amended Complaint in Divorce on or about January 31, 2005, requesting a divorce based upon section 3301 (d) of the divorce code, alleging that the parties had been separated for more than two years. SAlOIS, FLOWER & UNDSAY ATIOR.'\n~'AT,lAW 26 West High Street Carlisle, PA .. 7. Defendant filed a Counter-Affidavit under section 3301 (d), on February 17, 2005, indicating her desire to claim economic relief. COUNT I EQUITABLE DISTRIBUTION 8. The averments in paragraphs 1 through 7 are incorporated hereto as if fully set forth herein. 9. During their marriage, the parties have acquired certain property, both personal and real. WHEREFORE, Defendant requests this Court to equitably divide the marital property. COUNT II SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY 10. The averments in paragraphs 1 through 9 are incorporated hereto as if fully set forth herein. 11. Defendant is unable to provide for her reasonable needs In the standard of living established during the marriage. WHEREFORE, Defendant requests an award of Support, Alimony and Alirnony Pendente Lite. COUNT III INDIGNITIES 12. The averments in paragraphs 1 through 10 are incorporated hereto as if fully set forth herein. 13. Defendant is the innocent and injured party, and Plaintiff has offered such indignities to the person of the Defendant so as to rnake her life burdensome SAlDIS, ROWER & LINDSAY ATIORNEY~loAT'LAW 26 West High Street Carlisle, PA . her condition intolerable, in violation of the marriage vows and of the laws of the Commonwealth. WHEREFORE, Defendants requests this Court to enter a decree in divorce in accordance with the Pennsylvania Divorce Code. COUNT IV ATTORNEY'S FEES AND COSTS 14. The averments in paragraphs 1 through 11 are incorporated hereto as if fully set forth herein. 15. Defendant is unable to sustain herself during the course of this litigation or to pay the necessary and reasonable attorney's fees and reasonable costs and expenses. WHEREFORE, Defendant requests an award of counsel's fees and expenses Respectfully submitted, SAlOIS, FLOWER & LINDSAY Dated: )\/}i ;r([ I I J ! SAIDIS, FLOWER & LINDSAY ATIORMYS'AT'lAW 26 West High Sueet Carlisle, PA VERIFICATION I verify that the staternents made in the foregoing docurnents are true and correct. I understand that false statements herein are rnade subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsifications to authorities. Date: 'I-?~a (, '-/(;; II ~{f) ~j . . 2b / Lta )~U2J Sarbara A. Williarns ~~ 0;' F:. '--, -\ -l 'v ~ -S'. (""-'" '.J F:~ '--... ('"7> (""'" ~j0> "'-/ '--' If, \ -..." (;"'" \") <""", do i' Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. : No. 02-4936 CIVIL TERM BARBARA A. WILLIAMS, Defendant : CIVIL ACTION - DIVORCE PLAINTIFF'S MOTION FOR AN ORDER TO COMPEL DEFENDANT TO ANSWER INTERROGATORIES The Plaintiff, Eddie Williams, by and through his attorneys, The Law Offices of Patrick F. Lauer, Jr., L.L.C., hereby moves this Court to enter an Order pursuant to Pa.R.C.P. 1930.5(b) and 40 19( a)(1 )(i) for failure of Defendant, Barbara A. Williams, to answer Interrogatories and in support thereof avers as follows: 1. Petitioner is the Plaintiff, Eddie Williams. 2. Respondent is the Defendant, Barbara A. Williams. 3. On October 10,2002, Plaintiff filed a Complaint for a Divorce under S3301(c) and on January 31,2005, Plaintiff filed an amended Complaint for Divorce under S3301(d). 4. On April 28, 2006, Defendant filed a Petition for Economic Relief, Support, Alimony Pendente Lite, Alimony, Counsel Fees and Costs. 5. Interrogatories were sent to Defendant's counsel, servIce was accepted by Defendant's counsel on March 10,2005. See attached Exhibit "A". 6. Defendant's verified answers to the Interrogatories were due on or before April 10, 2005. 7. Plaintiff has not received any verified answers to the Interrogatories. 8. Plaintiff is entitled to answers to his Interrogatories because the information is relevant to the counts for economic relief. 9. Plaintiff has made a good faith effort to resolve this discovery dispute. " 10. On May 17, 2006, Plaintiff's counsel sent a letter to Defendant's counsel indicating that answers to the Interrogatories had not been received. See attached Exhibit "B". 11. In order to avoid court involvement, on July 10, 2006, Plaintiffs counsel sent a letter to Defendant's counsel indicating that answers to the Interrogatories had not been received. See attached Exhibit "C". 12. Defendant's verified answers to the Interrogatories have not been received. WHEREFORE, Plaintiff, Eddie Williams, respectfully requests this Honorable Court to order Defendant, Barbara A. Williams, to provide verified answers to the Interrogatories within (20) days. Respectfully submitted, ~ Date: August 29,2006 Marli Law Office of Patrick F. Lauer, Jr., L.L.c. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 . . EXhib\t A Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA EDDIE WILLIAMS, v. : CIVIL ACTION - LA W BARBARA A. WILLIAMS, Defendant : NO. 02-4936 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I, Marylou Matas, Esquire acknowledge that on or about March 3,2005, I received copies of Plaintiffs Interrogatories and Request for Production of Documents directed to Defendant, in the above captioned action and acknowledge that I am authorized to do so on behalf of Barbara A. Williams. Date: 3/ I 0/05 , f I U' -- l' ~ ' .," ,,, - /" , ! ',\ ,I' .... i /1 f"'L< C Cf / C{.., 7t (c .Q Marylolt M~tas, Esquire GRIFFIE-&' ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ,......, = i:;::.::) c.J'\ -". .,...,:~ '):1,:1:1' :;'\J J:""' -a -lI"l'" -".)" r .. o v.) EXhib\t B THE LAW OFFICES OF PATRICK F. LAUER, JR., L.L.C. 2108 MARKET STREET, AZTEC BUILDING CAMP HILL, PENNSYLVANIA 17011 (717) 763-1800 FAX (717) 763-4247 Reply to Camp Hill Address Patrick F. Lauer, Jr., Esq.* Marlin L. Markley, Esq.** Shana M. Pugh, Esq. 1-800-822-4-LAW Satellite Office: 8 S. Hanover Street Carlisle, PA 17013 .. ...................... _ dn;_p'" "nm May 17, 2006 Marylou Matas, Esquire 26 West High Street Carlisle, P A 17013 RE: Williams v. Williams, Divorce Cumberland County No. 02-4936 Dear Marylou: Enclosed are Eddie Williams' answers to your interrogatories and request for production of documents. He is currently working on obtaining values for his 40lk closer to the date of separation and his most recent value. I have also instructed him to have an appraisal done on their residence located at 20 Jane Lane, Carlisle, Pennsylvania. I will forward these documents once I have received them. I am requesting that you provide me with your clients answer's to Plaintiff's Interrogatories and the documents requested in Plaintiff's Request For Production of Documents. I believe thirty days from today's date is fair. In the meantime, if there is anything that you would like to discuss regarding this case, please contact me. Sincerely, MLM/ CC: Eddie Williams Enclosures @*Board Certified as a Criminal Trial Advocate by the National Board of Trial Advocacy. **eMember: National Association of Criminal Defense Lawyers Exhibit Q. THE LAW OFFICES OF PATRICK F. LAUER, JR., L.L.C. 2108 MARKET STREET, AZTEC BUILDING CAMP HILL, PENNSYLVANIA 17011 (717) 763-1800 FAX (717) 763-4247 Reply to Camp Hill Address Patrick F. Lauer, Jr., Esq.* Marlin L. Markley, Esq.** Shana M. Pugh, Esq. 1-800-822-4-LAW Satellite Office: 8 S. Hanover Street Carlisle, PA 17013 .,.... ............ W1IIW rini_p" "nm July 10, 2006 Marylou Matas, Esquire 26 West High Street Carlisle, P A 17013 RE: Williams v. Williams, Divorce Cumberland County No. 02-4936 Dear Marylou: As you may recall on May 17,2006, I forwarded to you Plaintiff's Answer's to Defendant's futerrogatories along with requested documents. At that time I also requested that you provide me with Defendant's Answer's to Plaintiff's futerrogatories, which answers were due on or before June 16, 2006. I have not yet received your answers. Please forward your answers to these futerrogatories to me no later than August 1,2006, to avoid court involvement. I look forward to receiving the requested answers and information. MLM/ CC: Eddie Williams @*Board Certified as a Criminal Trial Advocate by the National Board of Trial Advocacy. * '" fJ'!:J; Member: National Association of Criminal Defense Lawyers II EDDIE WILLIAMS, Plaintiff v. BARBARA A. WILLIAMS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 02-4936 CIVIL TERM : CIVIL ACTION - DIVORCE CRRTTFTCATR OF SRRV1CR I, Marlin L. Markley, Esquire, hereby certify that I have served a true and correct copy of the foregoing PLAINTIFF'S MOTION FOR AN ORDER TO COMPEL DEFENDANT TO ANSWER INTERROGATORIES upon the Defendant's counsel, by depositing a copy of same in the United States Mail, certified mail, return receipt, as follows: Marylou Matas, Esquire 26 West High Street Carlisle, PAl 70 13 Date: August 29, 2006 ~.. Marlin L ar ey, Esquire Law Office fPatrick F. Lauer, Jr., L.L.c. 2108 Mark t Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 o ( -,) r"\.,.~ (,0.-7 t,,-, f'o.., -::) .., (2;!'", ~ 2;J f'h;;g -rJi'l1 .uC:::; ( " ! .:).~~) _",,;'_1-. c- C') (A) c::; )'l .I' ", _ r',", , .J ,Jr" :fi' "" , ..... EDDIE WILLIAMS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW BARBARA A. WILLIAMS, Defendant NO. 02-4936 CIVIL TERM ORDER OF COURT AND NOW, this 1st day of September, 2006, upon consideration of Plaintiff's Motion for an Order To Compel Defendant To Answer Interrogatories, a Rule is hereby issued upon the Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, ()~ '\ pfJ o :rc S.' VfNV/\lAS\Jj\J3d , INn'" " '----..""n'" I\..L 1 ~\,).;""'~":j ~r ...; L'I : II ~IV 1- d3S SOOl AiNW';OHJDUd 3Hl :JO 3:jU}O-(!:J11:l . '.... SAIDIS, FLOWER & LINDSAY ATIORNEYSoAT.IAW 26 West High Street Carlisle, PA DDIE WILLIAMS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 02-4936 (") C ARBARA A. WILLIAMS, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT \.Ci AND NOW, comes Barbara A. Williams by and through her counsel arylou Matas, Esquire, and the law firm of Saidis, Flower & Lindsay, and states s follows: 1. The parties hereto are Husband and Wife having been joined in marriage on June 7, 1980. 2. The parties separated on or about October 10, 2002. 3. Petitioner is without the ability to earn income sufficient to meet her reasonable needs and to pay attorney's fees. 4. Petitioner filed a Petition for support, alimony pendente lite, alimony, counsel fees, costs and expenses on April 28, 2006. 5. To date, a hearing on this matter has not yet been scheduled. WHEREFORE, Petitioner prays this Honorable Court to set the matter of alimony pendente lite for a hearing before the Office of Domestic Relations. Respectively Submitted, Dated: 10/ S/D0 Marylo atas, Esquire Attorney ID: 84919 26 West High Street Carlisle, PA 17013 Attorney for Defendant r-...:t C':':) C-oJ A... o -Tl :r1 nlp::I ~g0 ~~-.:~ ~.~- ,l . ,., -r :._~ ~~~ '\.,_.....J :-"-r ;.'::1" ~J -<. o ("-;. --i I ~ -<:1 C,,,) (_...1 - -, SAIDIS, HOWER & LINDSAY ATIORNE\'S'AT-lAW 26 West High Street Carlisle, PA VERI FICA TION I verify that the statements made in the foregoing documents are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsifications to authorities. Date: '-:/2;1 A j(11/;J 0 t d / / .6 /1. ~ ~rbara A. Williams /0 'S--00 .. *., SAIDIS, FWWER & LINDSAY ~AT.L\W 26 West High Street Carlisle, PA CERTIFICATE OF SERVICE I, Marylou Matas, Esquire, of the law firm of SAlOIS, FLOWER & LINDSAY, ereby certify that on this date a copy of the attached document was served on the lIowing individual, via certified mail, return receipt requested, postage prepaid, ddressed as follows: Marlin L. Markley, Jr., Esquire Law Offices of Patrick Lauer, Jr. 2108 Market Street Camp Hill, PA 17011 SAlOIS, FLOWER & LINDSAY SAlOIS, FLOWER & LINDSAY ,(rroRNE\lMT.lAW 26 West High Street Carlisle, PA " EDDIE WILLIAMS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4936 Plaintiff v. BARBARA A. WILLIAMS, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, comes Barbara A. Williams by and through her counsel Marylou Matas, Esquire, and the law firm of Saidis, Flower & Lindsay, and states as follows: 1. The parties hereto are Husband and Wife having been joined in marriage on June 7, 1980. 2. The parties separated on or about October 10, 2002. 3. Petitioner is without the ability to earn income sufficient to meet her reasonable needs and to pay attorney's fees. 4. Petitioner filed a Petition for support, alimony pendente lite, alimony, counsel fees, costs and expenses on April 28, 2006. 5. To date, a hearing on this matter has not yet been scheduled. WHEREFORE, Petitioner prays this Honorable Court to set the matter of alimony pendente lite for a hearing before the Office of Domestic Relations. Respectively Submitted, Dated: I 01 S / () 0 Marylo atas, Esquire Attorney ID: 84919 26 West High Street Carlisle, PA 17013 Attorney for Defendant '... SAIDIS, FLOWER & LINDSAY XIlORNEYS.Kf.lAW 26 West High Street Carlisle, PA " VERIFICATION I verify that the statements made in the foregoing documents are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. e.s. ~4904, relating to unsworn falsifications to authorities. Date: 'fj/JAi<1///1 a. UJd/Aa~ rbara A. Williams /0 --S-:-00 " SAIDIS, FLOWER & LINDSAY MIORNlMMT.LAW 26 West High Street Carlisle, PA II CERTIFICATE OF SERVICE I, Marylou Matas, Esquire, of the law firm of SAlOIS, FLOWER & LINDSAY, ereby certify that on this date a copy of the attached document was served on the lIowing individual, via certified mail, return receipt requested, postage prepaid, ddressed as follows: Marlin L. Markley, Jr., Esquire Law Offices of Patrick Lauer, Jr. 2108 Market Street Camp Hill, PA 17011 SAlOIS, FLOWER & LINDSAY \;' ~ 'Z ?- ~ ~ r- ~ ... ~ ,L ? ~ 7'\> D '"" i. ; r- r',,') r..:) :.l \'.-" -. :~) -n c-' ....., "'-./ (J~; ( ) I..~" ,.1 .<~ EDDIE WILLIAM, PlaintiffJRespondent THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE BARBARA A. WILLIAMS, Defendant/Petitioner NO. 02-4936 CIVIL TERM IN DIVORCE PACSES CASE NO: 296108675 ORDER OF COURT AND NOW, this 10th day of October, 2006, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on November 2.2006 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, P A 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 191O.11@ (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Marylou Matas, Esq. Marlin Markley, Esq. tI, /l.u~ 'R. J. S~J day, onference Officer ( I YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND ' . . REPRESENT YOU. 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 MAY GET LEGAL HELP. Date of Order: October 10, 2006 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 r-:> C:::J ~~ a \? ~ o -----; '" tV 0,:' EDDIE WILLIAMS, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA VS. CIVIL ACTION - DIVORCE BARBARA A. WILLIAMS, Defendant/Petitioner NO. 02-4936 CIVIL TERM IN DIVORCE P ACSES # 296108675 ORDER OF COURT AND NOW to wit, this 2nd day of November 2006, it is hereby Ordered that the above captioned case is referred to the Support Master for a hearing and adjudication on the Alimony Pendente Lite and counsel fees matter. BY THE COURT: EdW~d~~ DRO: RJ. Shadday xc: Petitioner Respondent Marlin L. Markley, Jr, Esq. Marylou Matas, Esq. J, Service Type: M Fonn OE-OOI Worker: 21005 '" , , .... , C) r-J = C = c~... I ["..,) -0 G) oJ'C,.._ 01 =2 r,) .. . ,~ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BARBARA A. WILLIAMS ) Docket Number 02-4936 CIVIL Plaintiff ) vs. ) PACSES Case Number 296108675 EDDIE WILLIAMS ) Defendant ) Other State ID Number ORDER OF COURT You, EDDIE WILLIAMS plaintiff/defendant of 20 JANE LN, CARLISLE, PA. 17013-1034-20 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the at 8: 30AM for a hearing. :z <::) ~ DECEMBER 7, 2006 ...... c::::> c::::> cr You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: ):> Q N -1 Service Type M Form CM-509 Worker ID 21302 (, ....... WILLIAMS V. WILLIAMS PACSES Case Number: 296108675 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: ~ \-3-\J~ r::-~.~.? ~'... 1Ii'.",.1 ,. " JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGmLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (71 7) 240 - 6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Worker ID 21302 Service Type M ..r:- t...,) "" = ~~~ c-. ~ c.5 .....r.:,: o 1", ::"-f :t-,., rn-~, r- l:1rt: =uo .}~.; ~:~? 0 {-j ITl ~F5 -< , w -n :;,c o - ..-' In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION BARBARA A. WILLIAMS ) Docket Number 02-4936 CIVIL Plaintiff ) vs. ) PACSES Case Number 296108675 EDDIE WILLIAMS ) Defendant ) Other State ID Number ORDER OF COURT You, BARBARA A. WILLIAMS plaintiff/defendant of 20 JANE LN, CARLISLE, PA. 17013-1034-20 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the DECEMBER 7, 2006 at 8: 30AM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as f1led, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you S. information relating to professional licenses 6. other: Service Type M Form CM-S09 Worker ID 21302 . ~ WILLIAMS v. WILLIAMS PACSES Case Number: 296108675 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: _\ , - "3 - ~ C~2 , . ! .. ,~' '. , , . '" ,-",: JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Worker ID 21302 Service Type M -.c< ___1 ........J .... r-..:> c= = 0'" ;;p- eS ....:;: I W o ..,., ....... :r III :::D f- en q ~;) .oj__: cC; rrl w .. ;;:- W EDDIE WILLIAMS, PlaUntifDltespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA VS. CIVIL ACTION - DIVORCE BARBARA A. WILLIAMS, DefendantIPetitioner NO. 02-4936CIVIL TERM IN DIVORCE P ACSES # 296108675 ORDER OF COURT AND NOW to wit, this 9th day of January 2007, it is hereby Ordered that, pursuant to an agreement of the parties and their counsel, the request for a hearing de novo is withdrawn. The petition for Alimony Pendente Lite is dismissed without prejudice, and this case is closed. BY THE COURT: ~ Edwar~ ~ ~Ui , , J. DRO: RJ. Shadday xc: Petitioner Respondent Marylou Matas, Esq. .Marlin L. Markley, Esq. Service Type: M Form OE-OOI Worker: 21005 (') ~ ~ "'Oc'" tI1r:' ~:".,' (/) 5. ....... _'."0. r-: (" .~ ,~- z(,~ "';.-0 -"c Z =< "" <;::) <;::) ~ <- ::::- Z , \0 ~ ~21 ~[;:; :1)0 01- :?~ ~5 :ri 70 om -t ?5 -< ""0 :x ~ .::- -.J