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IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
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STATE OF
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CONNIE L. BADGER,
:'\: (l, 96-5525 CIVIL..TERM
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Plaintiff
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KENNETH H. BADGER I
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Defendant
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DECREE IN
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AND NOW. ~~ '2.-. . 19 "... ;1 " "d".d and
decreed that", , . ",' ,.CON,NIE.~. ,BAj)GER"",," ,'" ". plaintiff,
and, "" " " , " '" ,,', . .KI;:~N,E;'I:I:I, !l,',Il!\Dc;E~, , ., ,," ,',' ,,' '. defendant,
ore divorced from the bonds of motrimony,
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which 0 final order has not yet
been entered;
None
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CONNIE L. BADGER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
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i, KENNETH H, BADGER,
Defendant
vs.
CIVIL ACTION. LAW
NO.96.5525 CIVIL TERM
IN DIVORCE
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Ii PRAECIPE TO TRANSMIT RECORD
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. TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
I divorce decree:
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1. Grounds for Divorce: Irretrievable breakdown.
2. Date and manner of service of the Complaint:
Service upon Defendant on 1 5 October 1996
(See Acceptance of Service filed herein)
3. Date of execution of the Affidavit of Consent and Waiver of Notice required by
Section 3301 (c) of the Divorce Code:
By Plaintiff: 25 March 1997
By Defendant: 25 March 1997
4. Related claims pending: None.
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Sa uel L. Andes
Attorney for Plaintiff
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I CONNIE l. BADGER, IN THE COURT OF COMMON
Plaintiff PLEAS OF CUMBERLAND COUNTY,
II PENNSYLVANIA
II vs. CIVil ACTION. lAW
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II NO. 96- CIVil TERM
.1 KENNETH H. BADGER,
I Defendant IN DIVORCE
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NOTICE OF AVAilABILITY OF COUNSELING
TO THE WITHIN.NAMED DEFENDANT:
You have been named as the Defendant in a Complaint 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 3302(d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this
list is kept as a convenience to you and you are not bound to choose a counselor from this
list. All necessary arrangements and the cost of counseling sessions are to be borne by you
I and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice, Failure to do so will constitute a
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II waiver of your right to request counseling,
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II 9. During the course of the marriage, the parties have acquired numerous items of
1, property, both real and personal, which are held in joint names and in the individual names
of each of the parties hereto.
I WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by
I the Defendant, to equitably divide the property, both real and personal, owned by the
II parties hereto as marital property.
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WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to
the Divorce Code of Pennsylvania.
COUNT II - EQUITABLE DISTRIBUTION
COUNT III - ALIMONY
10, Plaintiff lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
11. Plaintiff is unable to support herself in accordance with the standard of living of
the parties established during the marriage through appropriate employment.
12. The Defendant is employed and enjoys a substantial income from which he is
able to contribute to the support and maintenance of Plaintiff and to pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding
Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate
to support and maintain Plaintiff in the station of life to which she has become accustomed
during the marriage.
COUNT IV - ALIMONY PENDENTE LITE
13. Plaintiff is without sufficient income to support and maintain herself during the
pendency of this action.
4
14. Defendant enjoys a substantial income and is well able to contribute to the
support and maintenance of Plaintiff during the course of this action.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her
reasonable alimony pendente lite during the pendency of this action,
COUNT V . COUNSEL FEES AND EXPENSES
15. Plaintiff is without sufficient funds to retain counsel to represent her in this
matter.
16. Without competent counsel, Plaintiff cannot adequately prosecute her claims
against Defendant and cannot adequately litigate her rights in this matter.
17. Defendant enjoys a substantial income and is well able to bear the expense of
Plaintiff's attorney and the expenses of this litigation.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal
fees and expenses incurred by Plaintiff in the litigation of this action.
I verify that the statements made in this Complaint are true and correct. I understand
I that any false statements in this Complaint are subject to the penalties of 18 Pa, C.S. 4904
(unsworn falsification to authorities),
DATE:
10- LJ _erl,
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CONNIE L. BADGER
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el L. Andes
A ttorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
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CONNIE L. BADGER,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
CIVIL ACTION - LAW
KENNETH H, BADGER,
Defendant
NO, 96-5525 CIVIL TERM
IN DIVORCE
MOTION FOR CONFERENCE ON ALIMONY PENDENTE LITE
AND NOW comes the above-named Plaintiff, by her attorney Sam'lel L, Andes, and moves the
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Court for a conference before the Domestic Relations Officer on her r~quest for Alimony Pendente Lite,
based upon the following:
1, The moving party herein is the Plaintiff,
2, Plaintiff, in her divorce complaint, a copy of which is attached to this motion, requested
Alimony Pendente Lite,
3, The Plaintiff now requests that a conference be scheduled before the Domestic Relations
Office on her request for Alimony Pendente Lite,
4, Plaintiff submits the following information about both parties:
Name
Current Address
Birth Date
Social Security Number
Connie L. Badger
113 Powells Valley Road
Halifax, P A
10-18-65
175-52-7065
Kenneth H. Badger
512 East Winding Hill Road
Mechanicsburg, P A
6-16-58
198-50-5364
WHEREFORE, Plaintiff moves the Court to schedule a conference before the Domestic
Relations Office,
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Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
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CONNIE L. BADGER, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNT V ,
) PENNSYLVANIA
)
vs, ) CIVIL ACTION - LAW
) NO. 96,56'2..S"'
) CIVIL TERM
KENNETH H. BADGER, I
Defendant ) IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHIS
Vou have been sued in court. If you wish to defend against the claims set forlh in tha
foregoing pages, you must take prompt action. Vou are warned that if you fail to do so, tho
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 childron.
When the ground for the divorce is indignities or irretrievable breekdown of the
marriage, you may request marriage counseling, A list of marriage counselors is available In
the Office of the Prothonotary at:
Office of the Prothonotary
Cumberland County Court House
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTV, LAWVER'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.
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Court Administrator, Fourth Floor
Cumberland County Court HOllse
Carlisle, Pennsylvania 17013
Telephone: (717) 240-6200
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CONNIE L. BADGER, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs, ) CIVil ACTION. lAW
)
) NO, 96. CIVil TERM
KENNETH H, BADGER, )
Defendant ) IN DIVORCE
NOTICE OF AVAilABILITY OF COUNSELING
TO THE WITHIN.NAMED DEFENDANT:
You have been named as the Defendant in a Complaint 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 3302(d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this
list is kept as a convenience to you and you are not bound to choose a counselor from this
list. All necessary arrangements and the cost of counseling sessions are to be borne by you
and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice, Failure to do so will constitute a
waiver of your right to request counseling.
2
CONNIE L. BADGER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs,
CIVIL ACTION, LAW
NO. 96,
CIVIL TERM
KENNETH H, BADGER,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above. named Plaintiff, CONNIE L. BADGER, by her attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is CONNIE L. BADGER, an adult individual who currently resides at
113 Pow ells Valley Road, Halifax, Dauphin County, Pennsylvania.
2, The Defendant is KENNETH H. BADGER, an adult individual who currently resides
at 512 East Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
wealth of Pennsylvania for at least six months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on 7 October 1989 in Halifax,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
~NLL - DIVORCE
8. The Plaintiff requests this Court to enter a Decree of Divorce.
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WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to
the Divorce Code of Pennsylvania,
COUNT II - EQUITABLE DISTRIBUTION
9, During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual names
of each of the parties hp.roto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by
the Defendant, to equitably divide the property, both real and personal, owned by the
parties hereto as marital property,
COUNT III - ALIMONY
10. Plaintiff lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage,
11. Plaintiff is unable to support herself in accordance with the standard of living of
the parties established during the marriage through appropriate employment.
12. The Defendant is employed and enjoys a substantial income from which he is
able to contribute to the support and maintenance of Plaintiff and to pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding
Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate
to support and maintain Plaintiff in the station of life to which she has become accustomed
during the marriage.
COUNT IV - ALIMONY PENDENTE LITE
13. Plaintiff is without sufficient income to support and maintain herself during the
pendency of this action.
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14. Defendant enjoys a substantial income and is well able to contribute to the
support and maintenance of Plaintiff during the course of this action.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her
reasonable alimony pendente lite during the pendency of this action.
COUNT V ' CQl.lli.SEl FEEaAND EXPENSES
15. Plaintiff is without sufficient funds to retain counsel to represent her in this
matter.
16, Without competent counsel, Plaintiff cannot adequately prosecute her claims
against Defendant and cannot adequately litigate her rights in this matter.
17, Defendant enjoys a substantial income and is well able to bear the expense of
Plaintiff's attorney and the expenses of this litigation.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal
fees and expenses incurred by Plaintiff in the litigation of this action.
I verify that the statements made in this Complaint are true and correct. I understand
that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S, 4904
(unsworn falsification to authorities),
DATE: ({)- ,,+- 90
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CONNIE L. 8ADGER
f:) -Sd..-.,v.e>( L A",~~~
Samuel l. Andes
Attorney for Plaintiff
Supreme Court 10 17225
525 North 12th Street
Lemoyne, PA 17043
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CONNIE I.. 1l^I)(jER .
PI.^INII FF/PI:TllION lOR
IN 1111: COURI OF COMMON PI.E^S 01:
('lll\lIlI:RI.^ND COUNlY. PI:NNSYI. V ^~I^
VS
CIVIl. MTION - I.^ W
KENNEll/II. 1I^f)(jI:R.
DEFI:ND^NT/RESPONDI:Nl:
NO, w,. 5525 CIVIl. TERM
ORnER OF COllRT
^ND NOW. this 8th day of November. 1996. based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $ N/^ per month and Respondent's monthly net
income/earning capacity is $ N/ ^ per month. it is hereby Ordered that the Respondent pay to the
Domestic Relations Seetion, Court of Common Pleas. $ 485,00 a month payable $ II~,OO ner week
as alimony pendente lite, effective 10/14/96, Mrcars set at $ 448,00 as of 11/8/96. shall be
payable at $ N/ ^ , First payment duc on or bcfore 11/12/96. and each month therealler.
Failure to make each paymcnt on time and in full will cause all arrears to bccome subjeet to
immediate eollection by all oflhc mcans as provided by 23 Pa.C.S.* 3703, Furthcr. if the Court
Iinds. aller hearing. that the Respondent has willfully failed to comply with this Order. it may declare
the Respondent in civil contempt of Court and its discretion make an appropriate Order. including.
but not limited to. commitment orthe Respondent to prison lor a period not to exceed six months,
Payments must be made by cash. check or money order, Cash payments must be made in
person, ^" checks and money orders must be made payablc to Domestic Relations Section and
delivered or mailed to Domestic Relations Section. 13 North Hanover Street. P.O. Box 320. Carlisle.
Pennsylvania, 17013, Each payment must bear your Domestic Relations number (DR _) in order to
be processed.
Respondent is responsible I<)r service Ices of 4,00 to be paid within sixtv davs as
determined by the Domestic Relations Section,
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CONNIE L. BADGER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION- LAW
NO, 96-5525 CIVIL TERM
IN DIVORCE
v,
KENNETH H. BADGER,
Defendant
ACCEPTANCE OF SERVICE
I hereby acknowledge that I received a true and correct copy of the Complaint in
Divorce filed in this action on or about October 15, 1996 and hereby accept service of same,
~er
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CONNIE L. BADGER,
Plaintiff
vs.
KENNETH H. BADGER,
Defendant
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· TO THE PROTHONOTARY:
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION. LAW
NO, 96.5525 CIVIL TERM
IN DIVORCE
PRAECIPE
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Please withdraw the claims for equitable distribution, alimony, alimony pendente lite,
Ii and counsel fees and expenses filed by the Plaintiff in the above-captioned action,
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Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761.5361
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CONNIE l. BADGER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION. LAW
NO, 96.5525 CIVIL TERM
KENNETH H. BADGER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
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i' 1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 7
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I: October 1996 and was served upon the Defendant on or about 15 October 1996.
Ii 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
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Ii days have elapsed from the date of filing of the complaint and the date of service of the
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\i complaint on the Defendant,
II 3, I consent to the entry of a final decree in divorce either after service of a Notice of
I'I Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Ii Intention to Request Entry of the Decree,
,i 4. I have been advised of the availability of marriage counseling and understand that
Iii the Court maintains a list of marriage counselors and that I may request the Court to require
,\ my spouse and I to participate in counseling and, being so advised, do not request that the
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II Court require that my spouse and I participate in counseling prior to the divorce becoming
Ii final.
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Ii I verify that the statements made in this Affidavit are true and correct and I
,
Ii understand that false statements herein are made subject to the penalties of 18 Pa, C.S.
,I
Ii Section 4904 relating to unswom falsification to authorities.
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Ii 3 ~ ,%>77
Ii DATE
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KENNETH H. D ~
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CONNIE L. BADGER,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
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CIVIL ACTION - LAW
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:; KENNETH H. BADGER,
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Defendant
NO. 96.5525 CIVIL TERM
IN DIVORCE
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i 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on -:
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Ii October 1996 and was served upon the Defendant on or about 15 October 1996.
,I 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
'II days have elapsed from the date of filing of the complaint and the date of service of the
complaint on the Defendant.
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3. I consent to the entry of a final decree in divorce either after service of a Notice of
AFFIDAVIT OF CONSENT
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
I Court require that my spouse and I participate in counseling prior to the divorce becoming
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I final.
I I verify that the statements made in this Affidavit are true and correct and I
II understand that false statements herein are made subject to the penalties of 18 Pa. C.S,
i: Section 4904 relating to unsworn falsification to authorities.
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CONNIE L. BADGER
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
CONNIE L, BADGER ) Docket Numhc:r 96-5525 CV
Plaillliff )
VS. ) PACSES Case Num"e, 118000062
KENNETH H, BADGER )
Defenuant ) Oth<, State ID Num"e,
PETITION FOR CONTEMPT - DEFENDANT
TO THE HONORABLE, THE JUDGES OF SAID COURT:
1. Petitioner is
County Domestic Relations Section.
CUMBERLAND
2. Defendant is
who resides at
KENNETH H, BADGER
802 FLINTLOCK RIDGE RD, MECHANICSBURG, PA, 17055-4918-02
3. On APRIL 4, 1997
an order of support was entered by the Honorable Court
per month for the support of
directing Defendant to pay the sum of $ 0,00
his/her dependent(s).
4. Defendant has failed to comply with the order as entered by theCOun-b
IX! pay as ordered.
o provide information which was ordered.
o appear as ordered.
IX! other:
4/2/97, APL ORDER WAS TERMINATED w/ BALANCE DUE & DEFENDANT
TO PAY IN 30 DAYS,
5. The arrearages under the Order amount to $ 702,00
as of JANUARY 25, 1999
WHEREFORE, Petitioner prays that the Court issue an order directing the attendance
of Defendant at a hearing of said Petition and hereafter to make an adjudication of contempt,
I verify that the statements made in this Petition are true and correct to the best of my
knowledge. I understand that false statements herein are made to the penalties of 18 Pa.
C.S. ~ 4904 relating to unsworn falsification to authorities.
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