The URL can be used to link to this page

Home My WebLink About00-00552 ". ,. - .- J -' ".- ~ - . ~'~, b._.~ ';'r" .~" - 1." ' ~, .- - ---.,.,-:.." Ui,' i I .5'+;'( :::~::.;~.:. '::~::.;( ):+;..::)::C<::..::.::~~~ )::.~~::::*::(:::.:C'(:;.::*f.::;'::c~;~)~::O;::x.::(',:~::.::<<)::.::.;:: }::C~;,: :~.::C{}>>X)f::.::<< :::~::c~:',:;.:!rXC,(~~f:+::'''l;~:::.~~>::.::i-,;:.::,~:+::~t::,!:::C<)>>::(:::~:::.x::'~:C~ft.~1 ~ --- . ;..~ ~ < ~ ~ ~.~ ~.l ~.~ 8 ~:~ ~ ~.~ ~.~ J t;) M ~.~ ~ ~ ~ ~.~ ~ ~' ~.~ ~.~ ~ ~~.. ~ ~.~ ~ ~.~ ~ ~.~ ~ ,d, ",,' ~ ~ " - i . ~ l...:(,..:.""~:.,,,,,,, ~.~ ~ a ~.~ ',.,,' * ~.~ ~ ~ ... ~ I ~.; ~ ~.-': ~ ~ ~.S ~ ~ ~ ~.~ ~ ~.~ \:'l f..~ .~ ~ ~.~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. STACY PATTERSON, ____u. __...___uu.. ...._. Versus uu I II 'I N 2000 - 552 VIVV o. u"",,""""""U'" u""""""""",",~ Plaintiff J:J;:F:];'RF;:Y:]>AT~J;:~~9N, "u u"" Def,endant.." u DECREE IN DIVORCE AND NOW, ,. .~.~. .<:-:':\.,.. ,~.~it is ordered and decreed that, . , , . .. . , ,s..t;~'?Y, .~~~:t.~r:~?!l, . . .,. . . , . , , , . , . ., , , . " plaintiff, and. .. . ' ., , . .. . , , , .. . .~~rf.r;~y, .~qtt!".:r:f.l9!1.. .. , . .. ,. .. . , . , , " defendant, ore divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of recp~d in this action for which a final order has not yet been entered; lIClAQ Further, the MaLi tal Settlement Agreement executed on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , ,S"p.temb.e.r ,12.,. .2002 .is.. .inco.:r:porated. into. .this, Dee;: and the parties are ordered to comply w' it. ~ . y. .r;6!fe;r:,ence By Th~ Con ( Attest: uua" uuuLumuuuuu " / Prothonotary - ~ _ .>>::( ';:'::.::'< ';.:C";: ':'.::C.;,_ _::.::c~,.: ",.::.::0.,. ::'.::+::!,:: "~::.::.": ".::.::.,. "'.::.::."- ';::.::." :.::.::.'" ~ ~ ~ ~ ,.:.:.:':.:.:.::.:.:.. 0:.:'::.:.:..0:.:....:.:..:.;.;.:.:...:.:. J. ~ ;..; , ''''. i ~.~ ~ ~.~ ~ i ~.~ ~ ~.~ ~ .. ~.~ I ~ i N ~ ~ I i ~.~ V ~ i~ t.S ~ ;'.s ~ ,;:~" ~ ~.~ a :..~ ~ .:.;:, ~ ~.~ '".". M ~.~ ~.~ ~ ~ "",' $. ~.~ ~.~ ~ ~ ~.~ ~.~ ~ ~ ~ ~.~ ~ ~.,' ~ ~ ~.~ ~ s ~ ... <'^ '"',. '.. >, . ,_ t, t;'. ,;2. //~~ ~. ~ Jt..~ ~ 4' ~ ~ ,.;;l/.o J- 71~ /U/:A/~, a7J ~ r, . <; .. . It. ~"." ...' .. ., .... " ~ , -,',' I'!"". ,on~",,_~ " ~~~~ ".......~ ", I ,:"'!"fIi' -l1 " . . ~ ~ ~i,~+ ! . .. STACY PATTERSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, No. 2000-552 CIVIL TERM v. JEFFREY PATTERSON, CIVIL ACTION - DIVORCE Defendant. NUUUTALSETTLEMENTAGREEMENT THIS AGREEMENT, made this l.;)+k day of ,~ f:ciDmkLoAJ, 2002, by and between STACY PATTERSON, hereinafter called "Wife", and JEFFREY PATTERSON, hereinafter called "Husband". WITNE SSETH: WHEREAS, Husband and Wife were legally married on September 27, 1997; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they desire to live separate and apart from each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations. NOW THEREFORE, in consideration of the premises and covenants contained herein, it is agreed by and between the parties hereto that: ~ , ~~ '"' ~ 1. NO-FAULT DIVORCE. Husband and Wife agree to secure a No-Fault Divorce based upon the irretrievable breakdown of the marriage. Husband and Wife agree to execute their respective Affidavits Of Consent under Section 3301 (c) ofthe Pennsylvania Domestic Relations Code and to execute any and all other documents necessary under existing law to expedite a final decree of divorce from the Court of Common Pleas of Cumberland County. 2. INTERFERENCES. Each party shall be free from interference, authority and control by the other except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest or attempt to endeavor to molest the other, or in any way harass or malign the other, nor in any other way interfere with the peaceful existence, separate and apart from the other. 3. DMSION OF REAL PROPERTY. (a) Husband currently resides in the marital home located atl084 Oyster Mill Road, Camp Hill, Cumberland County, Pennsylvania, which is owned by Husband. Husband agrees that he will be responsible for all expenses, including but not limited to, the monthly mortgage, taxes, utilities, upkeep, and maintenance of the home for the time in which he resided there and continues to reside there. (b) Husband will maintain possession ofthe marital home and release Wife from - 2 - , I , '. all liabilities andlor claims andlor damages andlor expenses, (including attorney's fees and legal expenses), that he may sustain, or become liable or answerable for, in any way whatsoever, or shall pay upon, or in consequence of Husband's default or any default with regard to mortgage payments or real estate tax payments which will or would result in any action on any bond or mortgage with reference to said residence. 4. DIVISION OF PERSONAL PROPERTY The parties have divided all personal property owned by them during the marriage. Should it become necessary at any time for either party to execute any titles, deeds or similar documents to give effect to this paragraph, it shall be done immediately upon request of the other party. Husband agrees to relinquish all rights, title, and interest he may have in any and all , l :_0- r~ ,: r. 5. PENSION PLAN. of Wife's pension(s), 401 (k)'s, profit sharing, or in any other monies Wife is or may be entitled to (; receive now or in the future. Wife agrees to relinquish any and all rights, title or interest she may have in any pensions, 40l(k)' s, profit sharing, or other monies that Husband may be entitled to now or in the future. 6. BREACH. If either party breaches any provision of this Agreement, the other party shall have - 3 - " the right, at his or her election, to sue for damages for such breach. The party breaching this contract shall be responsible for the payment oflegal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. 7. FULL DISCLOSURE. Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party of every type whatsoever and all other facts relating to the subject matter of this Agreement. 8. ADDITIONAL INSTRUMENT. Each of the parties shall on demand execute and deliver to the other any deeds, bills of sale, assignment, consents to change of beneficiary on insurance policies, tax returns and other documents and do or caused to be done any other act or thing that may be necessary or desirable to the provisions and purposes ofthis Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonably incurred as a result of such failure. 9. WIFE'S DEBTS. Wife represents and warrants to Husband that since the parties' separation she has not - 4 - and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband hann1ess from any and all claims or demands made against him by reason of debts or obligations incurred by her. 10. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the parties' separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 11. WAIVERS OF CLAIMS AGAINST ESTATES. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, to the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. - 5 - ,~-, ~,~,! i 11 :1 'I 1 II " II ,I I' ,I I'! ii Ii II II 11 11 'I I, , ,~ I~ f1 li " il " d :1 " " " I I i I ~ ~"'- 12. REPRESENTATION. It is fully understood and agreed that each party has the right to have advice of independent counsel prior to the signing ofthis Agreement. By the signing of this Agreement, the parties recognize that he/she fully understands the legal impact of this Agreement and waives hislher right to have the Agreement reviewed by an attorney ofhislher choosing, and further intends to be legally bound by the terms of this Agreement. 13. EFFECTNE AGREEMENT. This Agreement shall bind the parties, their heirs, executors, administrators and assIgns. 14. VOLUNTARY EXECUTION. The provisions of this Agreement are fully understood by both parties and each party acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily and that it is not the result of any duress or undue influence. 15. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties and there are no - 6 - ~ - " representations, warranties, covenants or undertakings other than those expressly set forth herein. 16. PRIOR AGREEMENT. It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 17. MODIFICATION AND WAIVER. Any modification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 18. GOVERNING LAW. This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth ofPelllisylvania. 19. INDEPENDENT SEPARATE COVENANTS. It is specifically understood and agreed by and between the parties hereto that each - 7 - -~ ~ . paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 20. VOID CLAUSES. If any term, cond i tion, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. I I ( !.j 21. ENTRY AS PART OF DECREE. It is the intention of the parties that this Agreement shall be incorporated, but not merged, in any final Decree in Divorce. 22. WAIVER OF CLAIMS. With the exception of the specific terms of this Agreement, the parties waive any claims they may have against the other under the Divorce Code of the Commonwealth of Pennsylvania including, but not limited to, alimony, alimony pendente lite, counsel fees, costs and expenses and equitable distribution. IN WITNESS WHEREOi', the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seeds the day and year first above written. - 8 - WITNESS: n~~ QA.^^A\ ~ ST YPATTERSON ) ~Q"..,^,"= FF YPATTERSOU 60 Ct-M. 0 AJ - 9 - ~~ ~ l..~et " "] ::;i , ''0 il jl I' l! i,1 Ii :1 11 I lj , ,:1 ii ,\i r: ; . ';! ~ : \1 I: Ii t: I ~! COMMONWEALTH OF PENNSYL VANIA COUNTY OF grn.lIH!Pl'L:illB'Da.uf'-ln ) ) ss: ) On this, the lJ..~ day of ~~ , 2002, before me, a Notary Public, personally appeared Stacy Patterson, known to me to be the person whose name is subscribed to the within Marital Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARIAL SEAL LINDA WITMER. Notary Public Harrisburg. Dauphin County, PA My Commission Expires 03-20-2004 dt~().J~ Notary Public COMMONWEALTH OF PENNSYL VANIA ) ) ss: COUNTY OF j _ -AlFJ "1111 U,6(./~p ) On this, the ~ day <; f ~d.L;: b _.." y; , 2002, before me, a Notary Public, personally appeared Jeffrey Patt~rso a, known to me to be the person whose name is subscribed to the within Marital Settlement Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHERE'JF, l hereunto set my hand and official seal. \ NoMF.-.r ~'U"~.~ ~~.~~ _1~~-'~~~~~~IiiII!IW:"~~~itliI:oj;?li"= "- _~li (( I' ~:=""'.:f"l!ft(,'A " \I!'lOOO nllIeitaCl ..qt!/T aulIafl, :9Wl)~ ! mtl~: ,,1t\llll~ ~ncO'iM 1",..,_......." '.. . ....._ ...~'" " ~~""""-~ (') S; -Oct': !::Dr: ~~7_, ",,::1-' ~2~:~':' ...~" ":- ~C~;.> ~~:3: , ~; -..; -< <:.':) (-'-.) o ", v:> :-,-, -0 -':"!] 1'-- :~:;c9 ~~ ') ti.., 2~'~ ~7:! :5 -<- Co ~ J, Ie . , " ~_ < '_ n" STACY PATTERSON, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. vs. No. 2000 - 552 Civil Term JEFFREY PATTERSON, Defendant. Civil Action - Divorce PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 330l(c) of the Divorce Code. 2. Date and manner of service of the Complaint: February 3, 2000 by certified mail, return receipt requested. 3. Date of execution of the Affidavit of Consent required by Section 330l( c) of the Divorce Code: by Plaintiff on August 9,2002; by Defendant on September 10, 2002. 4. Related claims pending: All claims settled pursuant to the Marital Settlement Agreement executed on September 12, 2002 and filed with this Court. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) of the Divorce Code was filed with the Prothonotary: August 14, 2002. 6. Date Defendant's Waiver of Notice in Section 330l(c) of the Divorce Code was filed with the Prothonotary: September 13, 2002. Respectfully Submitted, IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, PA 17102 Phone: 717-238-1657 BY:~B.t!J~ OHN B. DOU HE Y _~~~NIiii_ .:.........._.......-w~~:-~".-~...,.--".....1!III I.""'." -., 0 c;:') (: c N ~;: (/) ,-..; -r...t co CT1 J:,! SP. ~r, "':1 .-j ~ -, Z r - G UJ~: <Xl -<.?', ;~) r- ei -~o ~~ , '< -,: ~'. 0 .-" ,--) (') ~ () r::) ?i}' n l:: ~ -- :'f'1 :n ::;! t:,D ~~ t . ,- - - 'k' ,L- , <' STACY PATTERSON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02000 - S'S-~ Ci<,h'( y~ CIVIL ACTION - LAW IN DIVORCE JEFFREY PATTERSON, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree of Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the 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, PA 17013 (717) 249-3166 "~-, ~, .'-,i REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney J.D. No, 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No, (717)763-1383 Attorneys for Plaintiff STACY PATTERSON, Plaintiff v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO, .lrnn:> - 55 oZ- ~ ,- 1U-- JEFFREY PATTERSON, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is STACY PATTERSON, who has resided at 408 South Enola Drive, Enola, Cumberland County, Pennsylvania, for the last year. 2. Defendant is JEFFREY PATTERSON, who has resided at 1084 Oyster Mill Road, Camp Hill, Cumberland County, Pennsylvania, for the last fifteen years. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4, The Plaintiff and Defendant were married on September 27, 1997 in Camp Hill, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6, Neither of the parties in this action is presently a member of the Armed Forces, 7. The Plaintiff and Defendant are both citizens of the United States. 8, Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. h"""""\ Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. COUNT I - DIVORCE 9. The Plaintiff avers that the grounds on which the action is based are as follows: That the marriage is irretrievably broken. COUNT II - EOUITABLE DISTRIBUTION 10. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Chapter 35 of the Divorce Code, COUNT III - ALIMONY. ALIMONY PENDENTE LITE. ATTORNEY'S FEES AND COSTS II. Plaintiff lacks sufficient property to provide for her reasonable needs. 12. Plaintiff is unable to sufficiently support herself through appropriate employment. 13. Defendant has sufficient income and assets to provide continuing support for the Plaintiff. 14. By reason of this action, Plaintiff will be put to considerable expense in the preparation of her case in the employment of counsel and the payment of costs. 15. Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this action. 16. Plaintiffs income is not sufficient to provide for her reasonable needs and pay her ',,__.'k -.,,-,,;-;,---..,.., I."U attorney's fees and the costs of this litigation, 17. Defendant has adequate earuings to provide for the Plaintiff's support and to pay her counsel fees, costs and expenses, WHEREFORE, Plaintiff requests this Honorable Court: a, Enter a decree of divorce; b. Equitably distribute all property, both personal and real, owned by the parties; c, Compel Defendant to pay alimony pendente lite to Plaintiff; d. Grant Plaintiff attorney's fees and costs; e. Compel Defendant to pay alimony to Plaintiff. Respectfully Submitted: REAGER, ADLER & COGNETTI, PC Date: January 10, 2000 By: 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attorney for Plaintiff . - -, ~^ ~~nr, VERIFICATION I, STACY PATTERSON, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn verification to authorities, ~ ~M ~Jto~ STAC PATTERSON DATE: '/?,:l-!9 ) / . ~ (:) JQ ~ ~ -c.., --() ~~ ~ D "0 & ~\) ~~ ~ ~ ~ a o ' ti o ~ "- Ie;, ~ Cw ( ~~ ~ (") c: < urn n11~< z-:..'. zF-:~ cP.."2' -'< / <tJ ~c) ...c. c~ -.,...., -) ~c -7 :::; -< REAGER, ADLER & COGNE ATTORNEYS A TTI, P.C. T LAW C:~~1 MARKET STREET HILL, PA 17011-4642 (717) 763-1383 '." ~ o o () Tl :C-"" ,,~>- ..--, 'T~ L~ .;';:;;: :::J. C . I ~~ _~f'-1 ~~.~ Y :-:::1 s-:? -,., :i: ;--~,; -~-~ E\f;i, ::lJ -< - .. N "-", ",j - .,"-.-~ ;0(' REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney I.D, No, 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717)763-1383 Attornevs for Plaintiff STACY PATTERSON, Plaintiff : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYL VANIA v. NO, 2000-552 CIVIL TERM JEFFREY PATTERSON, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COlJNTI OF CUMBERLAND Before me, the undersigned Notary Public, this day, personally appeared Maria P. Cognetti, Esquire, attorney for the Plaintiff, to me known, who being duly sworn according to law, deposes the following: I, Maria P. Cognetti, Esquire, being duly sworn according to law, depose and state that service of the Complaint in Divorce in the above-captioned matter was served by Certified Mail, Return Receipt Requested, on Jeffrey Patterson, Plaintiff, on February 3, 2000. The Certified Receipt is attached hereto as "Exhibit A." REAGER, ADLER & COGNETTI, P.C. By: ;Ct fU,d:( MARIAP.CO Subscribed and sworn!i:.bbefore me this I r+ll day of n. rUAr't ,2000. N Publi Notarial Seal Karen A. Sherl1f, NotarY Public Harrisburg, Dauphin County My Commission Expires March 9, 2002 Member, Pe.1nsylvallia Association of Notaries l . .' ..' SSr-.m"'R: . ...."... :I -Complete Ite~ 1 antItEif'~'atlaltidni1f seMces. lD -Complete ItEm'lS 3._4a. and 4b. I -Print your name and address on the reverse of this form so that we can return this ij;;; card to you. = -Attach this form to the front of the -mailplece, or on the back if space does not ! permit. ~ .Wrj.tg. ~8etum Receipt Requested- on the mail piece below the article number. ti .Tti9\~ettJm Receipt will show 10 whom the article was delivered and the dale deljyerecl. c o 13~~~r:ff:::; ~~SO~ ~ \O~L\ a,-\~k.r mIll RC)a.cL to..mp l4LLL \ PPt nOl \ 5. Received By: (Print Name) II: :.!i ;) ig,\ J!! I also wish to receive the following services (for an extra fee):' 1. 0 Addressee's Addrass .~ ~ 2. 0 Restricted Delivery ell , Cons~lt postmaster ipr fee. 40. Article Number ? 3q "14313,-\- 4b. Service Type o Registered o Express Mall Retum Receipt- . . 7. Date of Deliv . Retum Receipt ad - .... B " II: E " 'i II: '" c ;; " .2 : " o >0' ... C .. .<: ... _'DiiiiIllIiiiIIa.J.. " .Ld....:.. " 1iI~~ , ,"' 1 d~"', " ~', ~- -~ ." ,',,~, ,.".~ ^",,-,,;-\ . '. () I;:;) ~ c-= 0 ;:-", -Or,': -n c:p 6~ rei :!:_~ ~,'~. co 6)\,: '-' -< :~ !:.= c~ j;: ----;;:, -'_/C"J ~. s:O ~'~' ~? :<i "J (,.) _C -', III ----'I ro__ -' <' L, - - ",;. ; h-' ,,"~ - - __ -' J; STACY PATTERSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. No. 2000 - 552 CIVIL TERM JEFFREY PATTERSON, Defendant. CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on January 31, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Dated: ~ Ji -O~ ~ .utv""V\..' ~()./;.k..7Ltl._ . STACY PATTERSON . '-'" ,~ =' _ C'-';-- ~-~ .~,~ ~ ~~1IWIiI "'~ , ",,:,- " ~- <"- .-< ~-- ";'< ".,~, (') c.:> 0 C ~"" ~n $: "'" -{ '1J C"'''' -r ~ L_ " rnrT G? :"'ii j= :z~-:o '-lr:-1 ~-;E .~ .:~-y c::c:> , "'to ~~~q "-. ':,-:;'; ~, :::r: ;~~~ rt? >:;7 :c: c ,~,) c -, ", -- :.v $ -< to -<, ~ "'" tl, <",--,:,;,;- -~,- - <":', -'~, ", -,,", , .~- ,c . ; ',.- 0-': ~~ I i , i l , . <"' STACY PATTERSON , Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. SS}.. No. 2000 - ~ CIVIL TERM vs. JEFFREY PATTERSON, Defendant. CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Dated: ~~q-Dd- P if ~ M~ fZ"":)~(Ji\AU1^, STACY PATTERSON v iiIiiIiIoio' '""'-'lill. If,_Jr~}) ",'1 ,",,') , < ,," ,~, ,.- "~ ,_. "', 1iM~-'" -, '-,> , J.I::J -" ~. ~Vl ~.~. ~.",~:-I ~'- 0 0 0 C N " ~:'"" "" ..:j "D'1" c::: ",1-.1 nlr-i': ~ ;'1i= Z:J_) -'C;m Zr-- '-'0 CD)- ' 'i.~ ._'~~ ! -<" .,' (:.:::c) ~~c-: ::S? ~C:n ):;;',--, ,-'"" :~() ::;-""\...;- >~ So" Oel! --i Z; ,""' '1>> -; :0 -<. '0 -< I'; ,:n " , ',:__ STACY PATTERSON, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. : No. 2000 - 552 CNIL TERM JEFFREY PATTERSON, Defendant. CIVIL ACTION - DNORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on January 31, 2000, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service ofthe Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Mfidavit are true and correct. I understand that false statements herein are made subject to the penalties ofl8 Pa.C.S. 94904 relating to unsworn falsification to authorities, Dated: ~b-0"2- ( )~jl~ ~"" _~~Ulltl- TIt '''~~"f '-i'" .-,t'>_:' ~ b. ',,",<, '. () (:.') ~~ -"-~ :n "0 r~.-: ,''1 rn ~~':J 2, :T Z r - (fJ->- C',) <j' 2~~-: ,--, , i ~\__J -0 d;:O _..,-;0 ~~ f{~ ~:=,6 Y;.c ~ Z 01 )> =< :lJ ...J -< J '. _-. " ~,-,,,~,.J,~',! STACY PATTERSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. ,-:li :ii' 'ii-: Plaintiff, vs. : No. 2000 - 552 CIVIL TERM JEFFREY PATTERSON, Defendant. CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights conceruing alimony, division of property, lawyer's fees or expenses, if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties ofl8 Pa.C.S. 94904 relating to unsworn falsification to authorities. Dated: Ot.y lO -O'Z-- ( ~, CJ~,..~ PATTERSON - .J '!! ""-J ~J. T l~M"--~ .tm!l~l_l .~M!i"""""~- ~ , " < ~l!' ~" _I o c <- -o6~ '-n,...:--, 2::7, ZC' (J),..,,-> -:< ,," r:'r: ~8 PC: :z =< ,~'~"'"'''' -,- '-,- --I< ".. ,"i ."<J c.: ,---, . " "~J -,.' ,I (~~i ,;~~ ;;2 i'-f~ ~.,.' ::n -< :;1 .....J iIlIll. __b_ _ ,_d. - " ~ -. '[-" \\Ntsb\flJll1ily law\Client Directory\Patterson. Stacy\Pleadings\patterson.pet_retum_prop,wpd * FeliruaJy25,2000 REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney LD. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attornevs for Plaintiff STACY PATTERSON, PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2000-552 CIVIL TERM JEFFREY PATTERSON, DefendantJRespondent : CIVIL ACTION - LAW : IN DIVORCE AND NOW, to wit, this lSL day of RULE TO SHOW CAUSE ~ooo, upon consideration of the within Petition, Respondent is hereby directed to show cause, if any, why the relief requested should not be granted. RULE RETURNABLE -1:[.:" from ~ire h=o[ ~~ ~ J, 1;.9- <S\MJJ. \t19- ~~ ti~ .(JL-Uw ~ BYTHECOURT:~- ( J~ ~/O~OO (<Kg "~ = FilED-OFFICE OF THE r:>:iOTHONOTARY 00 MAR 10 PH 2: 40 CUM8ERlmo COUNTY PENNSYLVANIA !l'IH . "< \_IIllII~ . --" .." <-..-,: \\NTSB\Family Law\Client Directory\Patterson. Stacy\Pleadings\patterson.pet-return-prop.wpd ~ Febmar128,2000 fi [i , LI REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney LD. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No, (717) 763-1383 Attornevs for Plaintiff STACY PATTERSON, PlaintifflPetitioner v, JEFFREY PATTERSON, DefendantJRespondent (1 'I II Ii ;! : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA f! ,. 'I 11 II 'I il " 1,1 II Ii !I 'I '. [-I : NO. 2000-552 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, to wit, this _ day of ,2000, upon consideration of the within Petition, it is hereby ORDERED and DECREED that within 10 days of the date of this Order, Respondent shall make arrangements with the Petitioner for the removal of her personal property. BY THE COURT: 1. . ~ . -"~ 0 ~ , I lOC~ \\Ntsb\family law\Client Directory\Patterson, Stacy\Pleadings\patterson,pet-retum-prop. wpd Febrmuy25.2000 REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney I.D, No. 27914 2331 Market Street Camp Hill, PA l70ll-4642 Telephone No. (717) 763-1383 Attornevs for Plaintiff STACY PATTERSON, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-552 CIVIL TERM JEFFREY PATTERSON, Defendant/Respondent : CIVIL ACTION - LAW : IN DIVORCE PETITION FOR SPECIAL RELIEF FOR THE RETURN OF PERSONAL PROPERTY AND NOW, comes the Petitioner, Stacy A, Patterson, by and through her attorneys, Reager, Adler & Cognetti, P .C., and files this Petition for Special Relief for the Return of Personal Property and in support thereof, avers the following: 1. Petitioner is Stacy A. Patterson, Petitioner in the above-captioned matter, who currently resides at 408 South Enola Drive, Enola, Cumberland County, Pennsylvania, 2. Respondent is Jeffrey A. Patterson, Respondent in the above-captioned matter, who currently resides at 1084 Oyster Mill Road, Camp Hill, Cumberland County, Pennsylvania. 3. Petitioner and Respondent were married on September 27, 1997 but separated on May 14,1998, 4. The circumstances surrounding the parties'separation unfortunately led to Petitioner leaving several items of personalty behind. --. ,-< ';.. ". ~ ' . \\NTSB\Family LllW\Client Dir~ctory\Patterson, Stacy\Plelldings\patterson,pet-retum-prop.wpd FebruarY28.2000 5. There were items of Petitioner' s which were either brought into the marriage or items such as clothing which were solely for Petitioner's use. 6. Petitioner has requested on several occasions that Respondent allow her back into the marital home to retrieve these items of property. By letters dated July 6, 1999, September 10, 1999, and November 3, 1999, Petitioner made these requests. Said letters are attached hereto and marked as Exhibits A, B and C, respectively. 7. The only response Petitioner received was a letter dated July 13, 1999, from Respondent's counsel wherein she indicated that she would have Respondent contact Petitioner to advise her of a convenient time for removal of her personal property. Respondent never discussed a date with Petitioner for the removal of her items of personal property. 8. Petitioner believes and, therefore, avers that there is absolutely no reason for Respondent to withhold her items of personal property. 9. Petitioner is not requesting the return of items of marital property at this time, 10. petitioner attempted for a period of several months to resolve this matter without the Court's intervention. Respondent would not cooperate, II, Petitioner has spent considerable time and expense on the preparation of this Petition. 12. Petitioner believes that Respondent should pay her legal fees for the preparation and presentation of this Petition. 2 _r- .'_<_' '.1-- ", , ~." ,~- ~ ., \\Ntsb\familY law\Client Directory\Pattersol1, Stacy\pleadings\pattersOll,pet_return_prop. wpd Februarf25,2OOO WHEREFORE, Petitioner respectfully requests this Honorable Court direct Respondent to provide her with access to the marital home for the purpose of removing her items of personal property . Respectfully Submitted: REAGER, ADLER & COGNETTI, PC Date: February 25, 2000 By: ;t{tU<Pc. 23 31 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attorney for PlaintifilPetitioner 3 - -. -,,-~ ~ ,,' . - ,- ,-'" ". - - '" ' t iJ. VERIFICATION I, STACY A. PATTERSON, hereby verifY and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S.A. ~4904 relating to unsworn verification to authorities, (D ~ -0>'\ DV\ r>1 -r- ~ 1) ~ STA~ A. PATTERSON DATE: J~~ g~{)O - ,.'''\ 'J_'" ".' _, " ~ ~, - ..:,.;,__', ,."-'--" -_",_, ,,J: j \\Ntsb\family Ill'P\Client Directory\Panerson, Stacy\Pleadings\panerson.pet-return-prop.wpd February 2S, 2000 CERTIFICATE OF SERVICE AND NOW, this ~day of February, 2000, I hereby verify that I have caused a true and correct copy of the foregoing Petition for Special Relief for the Return of Personal Property to be placed in the U.S. mail, first class, postage prepaid and addressed as follows: Jeffrey A. Patterson 1084 Oyster Mill Road Camp Hill, PA 17011 Date: February 25, 2000 By: REAGER, ADLER & COGNETTI, PC g~~. MARIA p( CO TI, ESQUIRE Attorney LD. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717) 763-1383 Attorney for Plaintiff/Petitioner 'c, "'-',, -," =~~"','" "" "_C_;.'".",' , -",-, ~-.~''''..i,; ';'d MARIA P. COGNETTI' Cognetti & Bradennan " JAY R. BRADERMAN tFellow, American Academy of Matri~onial Lawyers KAREN A. SHERIFF Paralegal July 6, 1999 BY FACSIMILE AND BY MAIL (717) 541-1429 Nora F. Blair, Esquire 5440 Jonestown Road P.O. Box 6216 Harrisburg, PA 17108-0216 RE: PATTERSONv. PATTERSON Dear Nora: Please be advised that Stacy has several items of personal property at the marital residence. She would like to be able to go in with her father or brother and pick up those items. I have instructed her that we should attempt to get a mutually convenient date before she enters the property. Therefore, she would like to be able to enter the property on one of the following dates: 1. July 7, 1999 in the evening 2. July 11, 1999 anytime 3. July 17, 1999 anytime Please discuss the above dates with your client and let me know which one works best for him. " It is my understanding that the parties' son is now in a new daycare. Stacy has done some checking on the daycare and does not feel comfortable with the provider Jeffrey has unilaterally chosen. Therefore, she will agree to keep Justin there until the parties have been able to find an alternate daycare provider. Stacy is in the process of meeting with and obtaining information from various providers and will give Jeffrey an opportunity to review and pick from the list. If Jeffrey has any alternate providers which he would like Stacy to consider, simply have him provide her with the names, addresses and phone numbers. Additionally, please be advised that rather than utilizing a daycare (717) 232-2103 . (717) 232-6600' Fax (717) 232-5775 200 North Third Street. Twelfth Floor' P.O. Box 689' Harrisburg, PA 17108-0689 "': "' ~ ,;"~-'~" - - '. - - - >'\ ,--~- -" - -',,,'<," .~"c ,~" ~., ',' ~ ....., i ,j 1 , lJ Ii II I I ~I Nora F. Blair, Esquire July 6, 1999 Page 2 provider during Stacy's periods of custody, her mother will be providing child care for her. As you may recall, prior to my involvement in this matter Emily Hoffman had forwarded to you a Custody Stipulation outlining an alternate custodial schedule. In reviewing Attorney Hoffman's file I do not see where you have ever responded to that proposed schedule. If you would, please take the time to pull it out and review it and contact me with any comments and/or changes you may have. Stacy believes the proposed schedule would be much more suitable to Justin's needs. Maria P. Cognetti, Esquire II [i [I I i il ~ M J ,I i ~1 'I " l:j 'I II II Ii , :~ ~ i I I :I :I I I I ,I I I i Last but not least, as you are aware, there is no Support Order in this matter. Stacy has, up to this point in time, been covering 100% of all of the uninsured medical expenses. She would ask that your client agree to reimburse her 50% of those expenses. We do not wish to institute a support action for these expenses, but if need be, will do so. Thank you for your attention to this matter. I look forward to hearing from you in the immediate future. Very truly yours, COGNETTI & BRADERMAN fl~/ ~/J<5 By MPC/drc cc: Stacy Patterson H:\Wp\CORRESPO\Patterson-Blair-ltr re child care and moo expenses.wpd "' ~,; ~'~ -,' ~" '"~,-, ',',;",- '= -,-'-'~---"---" "'I I I , I ! , Cognetti & Braderman Attorneys at Law t MARIA P. COGNETTI JAYR. BRADERMAN \ellow. American Academy of Matrimonial Lawyers KAREN A. SHERIFF Paralegal September 10,1999 Nora F. Blair, Esquire 5440 Jonestown Road P,O, Box 6216 Harrisburg, PA 17108-0216 RE: PATTERSONv. PATTERSON Dear Nora: As you may recall I wrote to you in the past regarding the retrieval of my client's personal property from the marital home, At that time I had given you several dates from which to choose so that my client could return to the home for her property. You basically put me off advising me that you and your client were considering the dates. However, those dates have now come and gone and I have had no word from you as to the retrieval of my client's personalty. Please be advised that, at this point in time, my client wishes to retrieve her property at once. Therefore I would like to hear from you within twenty-four (24) hours of your receipt ofthis letter as to how we can arrange for the return of my client's property. If! am compelled to seek the Court's intervention in this regard, I will certainly ask for counsel fees therein and would have no doubt that counsel fees would be awarded. This is a ridiculously minor issue over which we should not be wasting our clients' time and money. Secondly, you and I had briefly discussed the issue of changing the daycare provider. Please let me know your client's immediate intentions in that regard. I would hope that you would again remind him that he is under a Shared Legal Custody Order. I do not want to tell my client to take unilateral action in this regard, However, nor do I want to have to involve the Court on an issue oflegal custody, However, we want to remedy this situation immediately, and again I would request an immediate response from you, (717)232-2103. (717)232-6600. Fax(717)232-5775 200 North Third Street. Twelfth Floor. P.O. Box 689 . Harrisburg, PA 17108-0689 ""' Nora F. Blair, Esquire September 10, 1999 Page 2 - ~ ,- - , '; ,~.: --- - ".'-"- '-,c "~-, ' ' ;,<~" Finally, please reiterate to your client that my client does in fact wish to share the transportation duties regarding daycare. We can either start doing it on our own or we can all have a civil conversation about how this can best be accomplished. I will give your client the privilege of having input into how he would like to see this work. However, advise him that with or without his input we will in fact begin to share the daycare transportation at some point in the near future. I would rather do this under a program which works for everyone and will hope that you can get me a proposal in the near future. MPC/ddn cc: Stacy Patterson H:\Wp\CORRESPO\panerson -letter to attorney blair re personalty.wpd ... Very truly yours, COGNETTI & BRADERMAN By ... '"" -,-" ,. " ~ " ~" ",' "'~'"- '"" ,,","-- ~, '-";" 'i .taw Ollie" 01 Maria P. Cognetti 200 North Third Street Twelfth Floor P.O. Box 689 Harrisburg, PA 17108-0689 (717) 232-2103 fax (717) 232-5775 '~l,/'-"'- ::' ~; ~ : " " ,,' l ~ , f' tl , MARIA P. COGNErn' KAREN A. SHERIFF Legal Assistant q " \i I ii Practice Limited to Family and Matrimonial Law tFellow, American Academy ofMatrimoniaJ Lawyers November 3,1999 ~i ~ ! i " P ~ : '. f! . I I, I:: ~ : i" I l: u F:, H Nora F. Blair, Esquire 5440 Jonestown Road P.O. Box 6216 Harrisburg, PA 17108-0216 1m: PATTERSON V. PATTERSON Dear Nora: I. U If you check your correspondence in the above-referenced matter you will see that I wrote to you some time ago to request your assistance in gaining the return of my client's personal property. To date, unless I am missing a piece of correspondence, you have not even bothered to answer that request. I cannot fathom that you want to waste both of our clients' time and money in making me seek the Court's assistance. Therefore, I would greatly appreciate it if you would give me an answer to this question i~ediately. ii lJ 11 n " " Furthermore, as I had requested during the Support Conference in this matter, I would appreciate it if you would send me a definitive list of all of the employers to whom your client applied-for jobs. I would not only like the list but I would also request copies of his letters to those employers, Please let me know if this will not be forthcoming voluntarily. If that is the case than I will simply seek discovery through the Court and it will end up being much more extensive than the request contained herein, ": ',""'-'_'" ,'n'_'d ~ ,-J_-"'_~~_~~~-"-"" ~__';,d_.,_,' , Vi Nora F. Blair, Esquire November 3, 1999 Page 2 1[;1 i~! 1'" 1::1 I., i;:~ , I' I" , ", I(] I:';j " 'i I will look forward to hearing from you in this matter. "j .1 i'i ~1 ;i'! (DICTATED BUT NOT READ) ~! I~: ;:1 r:I 1'1 [I " " '1 , ~I ;1 " '1 :, , , , ;i ~) fi r~ ~! l~ ~" f: v: f1 [: l r' Very truly yours, Maria P. Cognetti MPC/tmg cc: Stacy Patterson H:\Wp\CORRESPO\pattenon-lctto ally blairre request for answer re peB01IaI property & job lists,wpd ", "1 Fi 1'1 [I l;! i" H i:i II ~ f! 'f !I 'J II ,. II i 'I I I I I I I I '" ~oouz l- W. , .' . '. - r (" , (~ 4J(:' , q.~.\~ : :.:;/1."..- ~} . t'~ii' ../ '--:;. .~~ -'- REAGER, ADLER & COGNETTI, P.C. ATTORNEYS AT LAW 2331 MARKET STREET CAMP Hill, PA 17011-4642 (717) 763-1383 -'n :.....,""\ ,,~., 'J'-" \:~ (j_J \...... . s.;? -:?" r...) '11-"- "-'-~ ,---, ,""' -"'~ 1_'_ REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney J.D. No. 27914 2331 Market Street Camp Hill, PA 17011-4642 Telephone No. (717)763-1383 Attornevs for Plaintiff STACY PATTERSON, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-552 CIVIL TERM JEFFREY PATTERSON, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND Before me, the undersigned Notary Public, this day, personally appeared Maria P. Cognetti, Esquire, attOnley for the Plaintiff, to me known, who being duly sworn according to law, deposes the following: I, Maria p, Cognetti, Esquire, being duly sworn according to law, depose and state that service of the Interrogatories (First Set) and Request for Production of Documents in the above-captioned matter were served by Certified Mail, Return Receipt Requested, on Jeffrey Patterson, Defendant, on March II, 2000. The Certified Receipt is attached hereto as "Exhibit A." . Subscrib~ and sworn to before me this 31!!. day of --fIla.A l' A 1f:;l)l~fJ ,2000. Notarial Seal Karen A. Sherill. Notary PubRe Herr(sbIJrg. Dauphin Cowlly My CommIssJoii ElIpires Meroh S, 2002 Memblll, Pennsylvania Aascci~OIl Of NolatiQlt ',-. -+~- -'~~'_':T,--"-~":'~7.-:-~-:i}:-\' ---,,--- -----.--- " -- , ~ SEN .R: . . ... .' .~.. !! .Complete items 1 and/or 2 for ~itfe1ita1:._ $l;_iM_. eta _.Complete iterns,3. 48; and 4b. ' 'T/ : . Print your name and address- on the nw8fS8 of this fonn so that we can return this ... card to you. I . Attactl thIs form to the front 01 the mailpiece, or on the back if space does not ! permiL <<>> -Write-Return Reeeipt Requested" on the mailpiece below the:J~rticle number. ..& -The Return AeceJpt will show to whom the artlde was deJlv9red and the date l5 delivered. I 3'~f~sse~;SOf) ~ (O'6L\ O-{~ (/\.u.L R:1 III Camp &U, ~ n6/J 5. Received By: (Print Name) ~~!t:;r~~ e"""tee): cIi 1. 0 Addressee's Address .!l ~ 2. 0 Res\IlctedOelivery III . Consu~ postmaster for tee. t 4a. ;q~r1Lfo ,Slj ~. 4b. Service Type ~ o Registered ~Certifled '; o Express Mail 0 Insured ~ Retum R$IJ8ipl for Msrchandise 0 COO :> . Date of DeIlVery .ll :> o ,.. .... liii .c. .., 8. Addresse . and tee is paid) ,. i' lJrn Receipt -''''; '1_0_ ,/ (') ~ So ;:gm _.JIn ~:tJ Z, (/).1.". :<2 kO 'P '"'~ , Z'J' '--0 :<>,:: REAGER, ADLER & COGNETTI, RC. ATTORNEYS AT lAW 2331 MARKET STREET CAMP Hill, PA 17011-4642 17171763-1383 ., (,' <', " . 'J ',:) "',,", " ~ " ",~"'. ~ ^ '''.'0>'' REAGER, ADLER & COGNETTI, PC MARIA P. COGNETTI, ESQUIRE Attorney I.D. No, 27914 2331 Market Street Camp Hill, P A 17011-4642 Telephone No. (717) 763-1383 Attornevs for Plaintiff STACY PATTERSON, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANJA v. : NO. 2000-552 CIVIL TERM JEFFREY PATTERSON, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND Before me, the undersigned Notary Public, this day, personally appeared Maria P. Cognetti, Esquire, attorney for the Plaintiff, to me known, who being duly sworn according to law, deposes the following: I, Maria P. Cognetti, Esquire, being duly sworn according to law, depose and state that service of the Rule to Show Cause with regard to the Petition for Special Relief in the above-captioned matter was served by Certified Mail, Return Receipt Requested, on Jeffrey Patterson, Defendant, on March 18, 2000. The Certified Receipt is attached hereto as "Exhibit A," REAGER, ADLER & COGNETTI, P .C. By: . ,2000. Notarial Seal Karen A. Sheriff, Notary Public Hallisburg, Dauphln CountY My CommlS~ ExpiI'8ll Marcil!!. 2002 Member. Pel1nsyl\Ianla Association 01 Notaries ~ ~, " J__",.>, Se,nd~r: :~ E : MARIA P ,"COGNETTIR, [lS.il!'W1RE REAGER,' ADLER & ,(OG~E7~I~ p~_~ 2331 MARKE~ STREET CAMP HILL. P~ 17Dl1 7. Date of Delivery ...llJ-'t:JO 48. Article Number Z. !:)82 tJ~-7 582 2'0 ' ,RESTRICTED DELIVERY 4b. service Type CERTIFIED , IIIIIII~II~ IIIII~IIIIIIIIIIIII ~111111111111111~1111;11111111~llllnlllll Z 9D2 D67 582 8. Addressee's Address (If different from address used by sender,) 3. Article Addressed to: I hhm'~hm,~mh'~hh'hmhhmm~~'hh~h~mhh'm~~~hh~mmm , Se.cDmlaIy Address I SvltlJ J Apt. J Floor (Please Print NS811y) I I ~m'~'~~m~hhh'~~hh'hhh~hhh~~'hh~~~hh~hh,,~~~h,~~hhh~hh~~ , Delivery Address I JEFFREY A, PATTERSON lD8~ OYSTER MILL ROAD CAMP HILL PA 17Dl1 .ciiy....---....--............---......-... -~W.il!:...........~.if)+.;f~~iil; lP_S~or"'._~11. Oecem'!.lJ,1'9t'1l _~_~!.___:-..~____~RETURN_RI:(;EIPTn /' , , 0 .=1 (: '~ C C:.J 5:_ ~ ""On " rnrr ~ ~ z~, 2T '-'-; w~;-- -<-' ~c .0 "!-- ~f :.:;: )> .~, r-~J ;';-''; ~, s:; , =) --'1 ......-'~ ...J -< REAGER, ADLER & COGNETTI, P.C, ATTORNEYS AT lAW 2331 MARKET STREET CAMP Hill, PA 17011-4642 (717) 763.1383 ,.. ~.' , "^ ,_, ~.o".., ^ STACY PATTERSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. No, 2000-552 Civil Term JEFFREY PATTERSON, Defendant. CIVIL ACTION - DIVORCE 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 20 days after this Affidavit has been served on you or the statement will be admitted. PLAINTIFF'S AFF'lDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in May 1998 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably ~broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in thiS Affidavit are true and correct. I understand that false statements herein are made subject to the penalties ofl8 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Dated: ~ 't 'JJPp I , , ~ oAV'VIV f<-~ , ----- S i\CY PATTERSON \" ~,e" J. ' - CERTIFICATE OF SERVICE AND NOW, this 22nd day of October, 2001, I, John B. Dougherty, Esquire, attorney for Plaintiff, hereby certify that I served the within AFFIDAVIT same in the United States mail, postage prepaid, in the post office at Harrisburg, Pennsylvania, addressed to: By First Class Mail: Jeffrey Patterson 1084 Oyster Mill Road Camp Hill, PA 17011 BY:~I3. ~~ OHN B. DOUG TY ~"I~ 't!llilll. ';1-.,."" ~~~~---<~' ilWi ,-' "I.... ':"'U"' :0:. '~- '~'., ~ 2 <' -oiii mn, z..,., p i3~:, -<.",- ~o ~8 >c: ~ ,,, a c~ '':'is z: a "< 2J '''diu -::'"79 ,\-:-fC; '--;---r, {''''1:n "::""-0 alii s:j :n -< .t:- J'>> :JJ: S" W $' Ul ~ 1"1 H . P<~ :z; :Z;:Z; 01"1 :>:P< :>: o - U>< E-< 1i<:Z; OP o E-< PO O:Z; U~ H 1"11>< :I:i:tl E-<~ :>: :Z;P HU ~"i'j:;'\c;:;Wi#-;,>'J,j~8tl1i1tf~ ",' "_""'d""~~-,=,.~~",.,~,,,,.d=Ju,,....i1i,,.",_,,~,,,,,,,-,,,,_,,,,,~~~,,,,,;,,,,<~~_~....,""""~~I,~",,",,.,,".iI,",""-".;.,I,lk;<;j"""^h~,""~I,""'" """_"""'<.",,~,.,,-~,I",,".J' ","k,~i",.""",",-,-,--,,,-,,,.,"---"~~,,,,,,,~",,,~." ..' '" 4-< 4-< .,.j +' C - .,.j :z; cO o .-I Ul P< 1"1 E-< E-< ~ P< > +' C cO - '0 :z; C o Q) Ul 4-< Q) 1"1 0 E-< E-< ~ P< >< 1"1 I>< Ii< Ii< 1"1 t-:l s ~ Q) E-< .-I .,.j :> .,.j U N L{) L{) I o o o N o :z; " ,-" ~-;o'",,/",,';i','-', 1"1 U I>< o :> H o I :z; o H E- H U ,;':;;,:,,}:"Hl:.t'gf'ti,J!M!!~;}""?,;1\-') I>< 1"1 o :z; P 1"1 E-<:I: HE-< :> ~Ii< 00 H Ii<- Ii< '0 ~- .-11"1 UlOO - M 0 Ii<MU Ii< H:Z;I"I E-<OU :Z;HI>< HE-< 0 ~U:> HI"IH ~UlO '~"', ,'> "l", . o ~ Il,; !'- ....~ :ti~ i:l:!: UJ [.) ~.~ ~OO(/J~ ::' Eo< 0 OZ" ~ ~ rJJ ~ '" 1'- ~ 0 Z _ oZ~OZ t: ~~"'S~&: <: (/J._ ....l Z~ 0" o <Il c:o '" ~ ~ (\j o "- 10 <0 - cO (':) CIl t == ~ ~ ~ ~ "' .J ~ () C;:J () C ,1 -.'>' -Ore ~ 5 tpm .c::: .,~ ......:0 1" 2S:;: :~,: fI{ ~"'< ...- ,,'...... ;'o) , '-:0 _:s~; ~ :;::::a~ L~ ::D 28 :::it '2 7C) ;Pc -f'11 Z S1 ~ w ;,> .;:- :;0 -< " ''- ""'-0.",",~~;,m'""~~~~_eom-~"'~;;l"',IMA'j',~~",'J,,,;o ;,;,.-,,1 ~4 "j._ ~ , , c '0"" ~'L 0,-,' n" In STACY PATTERSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, No. 2000-552 CIVIL TERM v. JEFFREY PATTERSON, CIVIL ACTION - DIVORCE Defendant. NOTICE OF INTENTION TO REQUEST ENTRY OF 3301 (d)])IVORCE DECREE TO: Jeffrey Patterson, Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the 3301 (d) affidavit. Therefore, on or after December 27, 2001, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary .of the court an answer with your signature notarized or verified or a counter -affidavit by .the above date, the court can enter a fmal decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief., A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. The filing of the form coumer-affidavit alone does not protect your economic claims. ".'- ' " :J~'~' , , ;1,)"_,'0.;,,.' , , . '., YOU SHOULD TAKE THIS P APER,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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA l70n 1-800-990-9108 . Respectfully Submitted, lRA H. WElNSTOCK, P.C. 8QONorth Second Street Harrisburg, P A 17102 Phone: (717) 238-1657 BY:~1l fJJ. LJ. .. OHN B. DOUGH TYi SQUIRE ID# 70680 Attorney for Plaintiff ;)rf ,.-""",.;- ",~ <- - - ,'",' "'C';' ~' , '"' ~.. "~,-- '" STACY PATTERSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANJA Plaintiff, No. 2000-552 CNIL TERM v. JEFFREY PATTERSON, CIVIL ACTION - DNORCE Defendant. COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) 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 Check (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 ifI 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 Of. 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 ofIntentionto Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 19 Pa. C.S. Section 4904 relating to unsworn falsification to authorities Date: Defendant NOTICE: If YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH .~. CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE TillS COUNTER A:FFlDA VIT. ""'~.1M.~k'~"",j.':' ~- . " __ c<'. 'j__ - ~,;' ',- , ,', CERTIFICATEOF SERVICE AND NOW, this 4th day of December, 2001, I, John B. Dougherty, Esquire, attorney for Plaintiff, hereby certify that I served the within NOTICE OF INTENTION TO REQUEST ENTRY OF 3301 (d) DIVORCE DECREE this day by depositing the same in the United States mail, postage prepaid, in the post office at Harrisburg, Pennsylvania, addressed to: By First Class Mail: Jeffrey Patterson 1084 Oyster Mill Road Camp Hill, P A 17011 Nora Blair, Esquire 5440 Jonestown Road Harrisburg, PA 17112 BY. :~~. {j tg~ . HN B. DOUGH TY .';;'"'~'r. -,u.., ~ ,,' ," J: ',<,-, ~li:lliiiil' " "~""~""'" "." -"""~ ' . ~' ., ,,' "" ,,",""'" ' , ,..., . ""'1 0 C) r~ ~-; '11 :::;~ (~:1 "'D UC' , '1 rn (j', c"') -, /.. , 2C' Cr.,! ~~ ~ <..;, ~C:-: ~) 2:; C) ::;C'; r;;> 0 Pc ---j ~ ~_n ~l.:: ~ \0 -< It ~ 12: ~g ....i>< Po.Ul 12: 12:12: Or=:! I~ o Ui>< E-l f><12: 00 o E-lU @5Q ~~ i:tlr=:! :~ HU . 12: o Ul ~ E-l ~ Po. i>' .."c"',-.c""",;,,,,,,,,_,_,~~_,","~","",,,,---,.~Id, """"'''''_'~'''' ~,,',' ,', I ""L"''',1...".. """ '"__,"', ~,-,,,,, ,,,0 """" ,I, I L., "'",__-"" . 4-1 4-1 ,~ .;J i:l ,~ ltl ..-I Po. . > .;J i:l ltl 'tl i:l Q) 4-1 Q) . Q ~ Ul Il:: r=:! E-l ~ Po. i>< ~ f>< f>< r=:! t-:> '~~'f';"'K'~',di~f('.;t'~~"""3",,,-wr..~~Pr,,,,,,";'-;r~*!7,GH,i,k,,,--;;;f,"-'K,~' ',"" ,""_,'n,;'" 0 ~ Q) E-l ..-I .~ > .~ U N lt1 lt1 I o o o N . ~ r=:! U Il:: s: H Q I 12: o H E-l U < .... H > H U '''''''''''.;"'00".",,,,<>'', '~'J,,.,t'''''',r':'':,,,,,,,,,,,,~,,,:-,',,;h'',,,'',- 'tl O~ E-l..-l o 12:M OM H E-lf>< 12:0 r=:! r=:! E-li><r=:! 12:1l::1l:: HE-lU 12:r=:! f><r=:!Q o E-lr=:! r=:!UlU Ur=:!1l:: HOO E-l0l> Or=:!H 12:Il::Q .,'.",,'''-'.,''''''''' ',,'."" '",J",I. , . . o - Po; I'- ...- :i ~~ 007 Ul 0 ~ OJ 00 Ji;; 1;3 ~~~~~Ir::: t.. 0 Z _ oZ~QZ f': ~ _ tLI tLI _ ~~r7lU:~ ....J" zg o ::> 000 <XlUl Q: Q: i C\l o r-- lQ (() t = ~ 1-1 ~ :c P.. ~ ~ 0 C) c::: <::- 1"::; 'TJ r~-'; L" -'~ C m ( ) Z :u Z , co :;I,~~ (.f', --( :~-~: ~~:.: CJ 'CJ '> T, LC' :". () -",- (~" Pc r:,? ~; '" Z U1 I::r~ =< :0 '" -< - ',; _.;=,,,"','~"""""l""'_'''''''",,,,,,'O_~- "~_"""""'1;'-"'""",<" ~,-."",,,,,...~-,,,,,, - ~........... II. " ~~~ - ~ ' ....'''l , I , 1 1 I , ~ STACY PATTERSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, No. 2000-552 CIVIL TERM v. JEFFREY PATTERSON, CIVIL ACTION - DIVORCE Defendant. COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): D<J [ ] (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because Check (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 ifI do not claim them before a divorce is granted. w (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 ofIntention to Request Divorce Decree, the divorce decree may be entered without further delay. I verifY that the statements made in. this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 19 Pa. C.S. Section 4904 relating to unsworn falsification to authorities ~ Date: 17.-21--e..) )~.\ ~. Defendant NOTICE: If YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER AFFIDAVIT. .- ~ ~ . ~. J~_'< 1IlJ!m~iHl\\'~ llOOIlI"' ~- , ~ ~ "~ ... .. 0 0 .'~ _J c: " s: a ..,- "'OC''') r"1 f,1~2J ~rn ,-, II N '.)':.!_~ Z:C ~d:::: -' t~~ ~CJ "". ~8 :;!l: ~o:::~~ ::r>c: 9 Q' -~ 7' t:"" ?Q -~ =< .l'"" -- , STACYPATl'ERSON, Plaintiff v. JEFFREYPATl'ERSON, Defendant . . , , : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-552 CIVIL TERM : CIVIL ACTION - DIVORCE ANSWER TO DIVORCE COMPLAINT And now comes Jeffrey Patterson and by and through his attorney, Nora F. Blair, Esquire, :files this Answer to Divorce Complaint and in support thereof avers as follows: l. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. No response required. 9. Admitted. COUNT I DIVORCE ~ ~" . , COUNT IT EQUITABLE DISTRmUTIONOF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 10. Admitted. WHEREFORE, Defendant respectfully requests that Your Honorable Court I I " I , i i i~ I' n enter an Order equitably distributing the marital property pursuant to Section 3502 of the Divorce Code. i~ COUNT ITl ALIMONY, ALIMONY PENDENTE LITE, AT1'ORNEY'S FEES AND COSTS I:: Ii , I I, I !'; 11. Denied. It is specifically denied that Plaintiff lacks sufficient property to 1'; i' , I , provide for her reasonable needs. To the contrary, Plaintiff makes more money than Defendant and has few expenses because she lives with her Ii> , ['^ i: , i-: parents. Additionally Defendant lacks sufficient property to provide for his reasonable needs. 12. Denied. It is specifically denied that Plaintiff is unable to sufficiently support herself through appropriate employment. To the contrary, Plaintiff makes more money than Defendant and has few expenses because she lIives with her parents. Additionally Defendant is unable to sufficiently support himself through appropriate employment. 13. Denied. It is specifically denied that Defendant has sufficient income and assets to provide continuing support for Plaintiff. To the contrary, Plaintiff makes more money than Defendant and has few expenses because she lives with her parents. Additionally Plaintiff has sufficient income and assets to provide continuing support for Defendant. ~- ~. - ^ --~~, -'^- ~ 14. Denied. Defendant is unaware of the expenses that Plaintiff mayor may not incur. By way of further response, Defendant has been put to considerable expense in the preparation of his case in the employment of counsel and the payment of costs. 15. Denied. It is specifically denied the Plaintiff is without sufficient funds to ;j rj support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this action. To the contrary, Plaintiff makes more money than Defendant and has few '. i1 [: 1'1 I' Ii Ii I; I: i l1 [1 expenses because she lives with her parents. Additionally Defendant is without sufficient funds to support himself and to meet the costs and expenses of this litigation and is unable to appropriately maintain himself during the pendency of this action. 16. Denied. It is specifically denied that Plaintiffs income is not sufficient to provide for her reasonable needs and pay her attorney's fees and the costs of this litigation. To the contrary, Plaintiff makes more money than Defendant and has few expenses because she lives with her parents. Additionally Defendant's income is not sufficient to provide for her reasonable needs and pay his attorney's fees and the costs of this litigation. 17. Denied. It is specifically denied that Defendant has adequate earnings to provide for Plaintiffs support and to pay her counsel fees, costs and expenses. To the contrary, Plaintiff makes more money than Defendant and has few expenses because she lives with her parents. Additionally . . Plaintiff has adequate earnings to provide for Defendant's support and to pay his counsel fees, costs and expenses. WHEREFORE, Defendant respectfully requests that Your Honorable Court enter an Order compelling Plaintiff to pay alimony pendente lite to Defendant, granting Defendant attorney's fees and costs, and compelling Plaintiff to pay alimony to Defendant. DATED: ,9~ 2( 2c>o / I submitted, o F. Blair Supreme Court ID #45513 5440 Jonestown Road Post Office Box 6216 Harrisburg, PA 17112-0216 (717) 541-1428 VERIFICATION I verify that the statement made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. )~~.~ . ,l' _ '_,',", ~',\ , . . .' STACYPATI'ERSON, Plaintiff v. : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-552 CIVIL TERM : CIVIL ACTION - DIVORCE JEFFREYPA'lTERSON, Defendant CERTIFICATE OF SERVICE I hereby certify that I have this date served a copy of the Answer to Divorce Complaint on the person in the manner stated. below which service satisfies the requirement of Pa.R.C.P. No. 440. SERVICE BY FIRST CLASS MAIL TO: John B. Dougherty, Esquire IRAK WEINSTOCK, P.C. Suite 100 800 North Second Street Harrisburg, PA 17102 Date: December 22, 2001 ;.~"-~Ifi' ~liliII "'-'- "-~ ,~ ,^ ""~ii!iili u. - ,', . ,,-~ () 0 (') c: 'Tl "'OS: 0 -.__1 ~Fg r'1 T';l,;r -n (J 2'5;.' N -,-,,!-n -,"':'''] se- ...., ,:.''-r ""- ~~~: ~:, {:::'O :>:>> """i, ~ ::r ~t~ ;;::0 (') Sf :J>c: ::--t :z r:- 2~ =< - ::0 - -< [0' flll.f.:ili'! STACY PATTERSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, No, 2000-552 CNIL TERM v. JEFFREY PATTERSON, CNIL ACTION - DNORCE Defendant. o , 2002, upon the request of AND NOW, this h day of Petitioner, it is hereby ordered that the hearing scheduled for August 5, 2002 at 1:30 p.m. is continued and rescheduled for September 18, 2002 at I :30 p.m. in Courtroom No.2, Cwnberland County Courthouse, Carlisle, Pennsylvania. " John B. Dougherty, Esquire for Plaintiff Nora Blair, Esquire for Defendant ~ ~ )P"7-O~ 9. r\lH)-(jfflCE ",e 'f\~.C D,~,,"\~\C:i\'\O\PR'I \j( ~ \ "- " ,-"" 02 f\\lG -0 ~\'\ 1..: \ G C'JMi3S::?,\j",'\\.) CO'JI'-I1'l ?'CNNS'IL'iI'l-{lf'.. I f 1", ',,~ _" 'C I~,- """""lilmlI!i~ ~""""-~= JIUI wm:11M _.,"'!!~ ,- ,;~~ ' '-" '. --"\O;~, -'-'" ,h"';. ,~ STACY PATTERSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, . No. 2000-552 CIVIL TERM vs. JEFFREY PATTERSON, CIVIL ACTION - DIVORCE Defendant. PRAECIPE TO WITHDRAW PETITION FOR BIFURCATION TO THE PROTHONOTARY: Please withdraw the Petition For Bifurcation filed in regard to the above- referenced matter. Respectfully Submitted, IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, P A 171 02 Phone: (717) 238-1657 By: ~~ 6. ~~ OHN B. DOUG ERT "'. '", . .. " CERTIFICATE OF SERVICE AND NOW, this 17th day of September, 2002, I, John B, Dougherty, Esquire, attorney for Plaintiff, hereby certify that I served the within PRAECIPE TO WITHDRAW BIFURCATION PETITION this day by depositing the same in the United States mail, postage prepaid, in the post office at Harrisburg, Pennsylvania, addressed to: By First Class Mail: Nora Blair, Esquire 5540 Jonestown Rd. P,O. Box 6216 Harrisburg, PA 17112-0216 The Honorable Edgar B. Bayley Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 By:~L3. &. ORNB. DOU E Y _1BIIIiIi!!lil1!illti,""".... """"'"W'" ~~,~ ,;t\liiiBiIIIIl(lilIflliiill~~~~"''''''''!.illIilIiIk!iI~!f;--.=J !jjl.iliiiiliII:- . o -U~ rnfT 7? 7.' zc ~7."- ~C-_' ....;'('" --::7',-, ).::~ :3 , c "-' U) ....., U r' U -n T' "1;~.:::-: ",-~ r"1 ~i~ 2~~ .- \-~ ''',', '~::~~~ ~, :.-;,~ ~ (;0 ---""'" 00 Ul \D - <' --, , STACY PATTERSON, PLAINTIFF V. JEFFREY PATTERSON, DEFENDANT AND NOW, this -.- - .L.' ~,'i 1 ~1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-0552 CIVIL TERM ORDER OF COURT ~ day of July, 2002, a hearing on the within petition to bifurcate a divorce action shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania, at 1 :30 p.m., Monday, August 5, 2002. John B. Dougherty, Esquire For Plaintiff Nora Blair, Esquire For Defendant :t/t1 p~ ~~1'''5,iJ:J..- 9.--, , ,~, -. ~<<< - ~> .- , f-fLf:D-~OFFICE 0'[: "-~ 0-, '(" '~-'RY , ;'":'<i..,:I r:,.:r-.;UiA [',,') J'll " ,'- , l..,_ -J fU'j 10: I I CUM8i:l~u'J'iU COUNTY PENNSYLVANIA , ',--">, _....,....". .. ~ - ,....,..,~, ,,~. "~ ,. M!Il!!!!'.~ ~- ,,"', , ..,,,.~, --'j'l]'- =,~~~"""'" "."""'~~ '^-,' ~'- ,-',' ,'..,:- , . '~" "' ;.,c.-"_>',c, _';,c,-, """>;;:,,-,..,,,,,,,,;',c,---<V.;',''-''~' STACY PATTERSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, No. 2000-552 CIVIL TERM v. JEFFREY PATTERSON, CIVIL ACTION - DIVORCE Defendant. PETITION FOR BIFURCATION AND NOW, the Petitioner, Stacy Patterson, by and through her attorneys, Ira H. Weinstock, P.C., files this Petition for Bifurcation and in support thereof avers the following: I. Your Petitioner is Stacy Patterson, Plaintiff in the above captioned matter. 2. Respondent is Jeffrey Patterson, Defendant in the above captioned matter. 3. The parties were married on September 27,1997 in Camp Hill, PA. 4. The parties separated in May 1998 and have continued to live separate and apart since that time. 5. On or about June 9, 1999, Plaintiff initiated the instant action by filing a Complaint in Divorce making ancillary claims for equitable distribution, alimony, alimony pendente lite, attorney's fees and costs. 6. Bifurcation will separate the termination of the marriage from the ancillary claims so that each party's personal life is no longer held hostage to economic demands. 7. Defendant will not be economically disadvantaged by being divorced. . , -. ' , ~ ~, " .'" "-',~' ',"' ^", ,="< '''-''1'','" - ,'-"'" ~ ""(,j l :J I:! II II iq il , , :,1 Ii 8, In Defendant's counter affidavit under Section 3301(d) of the Divorce Code, Defendant has indicated that he does not oppose the entry of a divorce decree. A copy of the affidavit is attached hereto and marked Exhibit "A". 9. Bifurcation will further encourage case settlement between the time the divorce decree is issued and the ancillary claims reach trial. WHEREFORE, Petitioner respectfully requests that this Honorable Court issue an order to bifurcate the divorce from the ancillary claims and Grant Petitioner a divorce. Respectfully Submitted, IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, PA 17102 Phone: (717) 238-1657 BY:~~ {3. ~~ OHN B. DOUG R 2 ",' ~- Plaintiff, INTHECOURTOFCOMMON~ CUMBERLAND COUNTY, PENNSYLVANIA STACY PATTERSON, No. 2000-552 CIVIL TERM v. JEFFREY PATTERSON. CIVIL ACTION - DIVORCE Defendant. COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): [ ] (ii) The marriage is not irretrievably broken. I I I i il :1 :1 i I i I , :1 il I II I I D<J [ ] (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because Check (i) , (ii) or both: [ ] (i) The parties to this action have not lived separate and apart for a period of at lea~t two years. 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 conceruing alimony, division of property, lawyer's fees or . expenses if! do not claim them before a divorce is granted. w (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 counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 19 Pa. C.S. Section 4904 relating to unsworn falsification to authorities ~ ~~ Date: , 2- 21-t./ ~ > \ . Defendant NOTICE: If YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVOR(,F. DECREE AND YOU DO NOT WISH ANY CLAIM FOR EeGo. :niJC RELIEF, Y Exhibit SHOULD NOT FILE THIS COUNTER AFFiDAVIT. "A" " ',-- '- ,,,," -_",..c_" ",_-,,,", """-",, _'.'''''-__'i'''>,,''' COMMONWEALTH OF PENNSYL V ANJA ) ) ss. COUNTY OF CUMBERLAND ) I verify that the statements made in the attached PETITION FOR BIFURCATION are true and correct. I understand that false statements herein are made subject to the penalties set forth in 18 Pa. C. S. 94904 relating to unsworn falsification to authorities. DATED: b I '1 t ?. <{xfn-- ~ oAH\/VI- f~-tJ~ TACYPATTERS N v c c ~ ..:.,~ , ',,;^- c ;;;, --0, c ~.~ c " ;, - CERTIFICATE OF SERVICE AND NOW, this 12th day of June, 2002, I, John B. Dougherty, Esquire, attorney for Plaintiff, hereby certify that I served the within PETITION FOR BIFURCATION this day by depositing the same in the United States mail, postage prepaid, in the post office at Harrisburg, Pennsylvania, addressed to: By First Class Mail: Jeffrey Patterson 1085 Oyster Mill Rd. Camp Hill, P A 17011 Nora Blair, Esquire 5540 Jonestown Rd. P.O. Box 6216 Harrisburg, P A 17112-0216 BY: ~f3. J:~ B, DOUGH TY 1iIM~ ... ""uilll!slL" '<'" ili_~.i'\i ~" ' '0"""' H"_O.""."" ., " ~. (') C ;;: -oG} qJ;~~ Zf'-': 0,~~~;: r::c] '" ~5~ )....c -? :';i ..... <-::J N <.- o -fi -~ -I::!J rl~ -,:;rn :U{:J :,;~6 -.,- " ~c5 Oni ;::-'f ..,:;" ::0 -< --.J c' c.,..., ::::> U\