The URL can be used to link to this page

Home My WebLink About00-00910 . . .. . o~ ~ >,. ''"1, -. '~- ff. Ef. '" Ef.,., Ef.Ef.Ef.Ef. Ef. Ef.Ef.Ef.Ef. Ef. Ef.Ef.Ef. .. :f.Ef.;f. "'''':Ii Ef.Ef. IN 'THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . PENNA. STATE OF . . . JAMIE L. RICKER, . . . plaintiff . VERSUS . . EARL J. RICKER, . Defendant No. 2000-910 Civil Term DECREE IN DIVORCE . AND NOW, 1112 f"c-L. I? , IT IS ORDERED AND DECREED THAT . . . AND 2001 JAMIE L. RICKER , PLAINTIFF, EARL J. RICKER , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . There are no outstanding claims. . . . ATTE PROTHONOTARY . Ef.Ef. Ef. Ef. Ef.Ef. Ef. Ef. Ef. Ef. Ef. Ef. Ef. Ef. Ef. Ef. ~, ~,-,"~, .~ ~~, " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . ,. ~-~ - '^'" '-" ~ '. 3/K);( W~ ~ ;G 4-~ .Jk~1 71~ ~~ -# ~ . ,~ """".~.l , "' , - ~- _ ~ -,~ ~1lQlII",""",~ r~'~< , ~ .-, .,-'"',--, ., -] -' .-," -~-,,~ ,',- ~<,= '.-;---;-;,~-'.,,:.~ i ,--,~ I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMIE L. RICKER, Plaintiff : No. 2000-910 Civil Term v. EARL J. RICKER, : IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: personal service on Februarv 16. 2000. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, Februarv 15.2001; by Defendant, February 22.2001. (b )(1) Date of execution of the Plaintiff's Affidavit required by Section 3301( d) of the Divorce Code: N/A (2) Date of filing and service of the Plaintiff's Affidavit upon Defendant: N/ A. 4. Related claims pending: There are no outstanding claims. 5. Complete either paragraph (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit ,~_. '.-,--,,\ ',- ;,,-"-'-',- ~-.; ,;. .-,- . . Record, a copy of which is attached: N/A. (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: February 21. 2001. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: February 28. 2001. ~~,~ MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 LD. # 61900 ~j~' . :llill~[ ;'i:.dlll!flili!:l.~~!,&,";_:EJ_IO!I>!l~ij;l;f,.Mit,"lirf"-= I ,." ~-. =- 1Iilll!!iifiIl;._ SJ '- 5:- \:.1 lJ~! r11 ~ T' ~~y -- o:!:;:,'-J ~b Pe- L: =< - , . CJ ~'2 " -rj C'l i]:J )'0 c,...,. (..J -:.r' 0) " -~ ..w~ _"1 ..;- I"-,--,-,, _,,-,,_-t...'". ," -,-- "-'''~-''':'i-l " " JAMIE 1. RICKER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA : NO. ..2Doo- q'/O e~..{ ~~ : CIVIL ACTION - LAW : IN DIVORCE EARL 1. RICKER, Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the . Prothonotary at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU 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 :i Liberty Avenue Carlisle, Pennsylvania 17013 Phone: (717)249-3166 ." "" ,.--,. - -,. '.' _~ '-;';~;:'_&'" _O';;>,-</~,C~ "__~ <'9 ! JAMIE 1. RICKER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA ; NO. :2...D-o-o - 9)0 c..wJ I Uv-.. EARL J. RICKER, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF A V AILABIUTY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 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 decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary . ~'. ~ 0" ,,-.'- -,.' ~.-- , '",---'---'-"" ,-~-"' '", ,i,eJ JAMIE L. RICKER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA : NO. .;Lo-v-v. 9/0 ~ I b- EARL 1. RICKER, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE I. Plaintiff is Jamie L. Ricker, who currently resides at 9 North High Street, Shiremanstown, Cumberland County, Pennsylvania 17011. 2. Defendant is Earl 1. Ricker, who currently resides at Lot #5, West Maple Avenue, Crestview Village, Middletown, Dauphin County, Pennsylvania 17057. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 9, 1998, in Shiremanstown, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. , . , ~, " "'",',,,..; ~-"'-'-= .>, _ " - ~_ .'. ,- i ., The parties to this action have been separated since October 16, 1998. 10. Plaintiff requests the Court to enter a Decree in Divorce. 11. Plaintiff avers that she is the innocent and injured spouse, and that the Defendant has offered such indignities to the Plaintiff so as to render her condition intolerable and life burdensome. 12. This action is not collusive. WHEREFORE, the Plaintiff requests the Court to enter a Decree in divorce dissolving the marriage between the Plaintiff and Defendant. JAMES, SMITH, DURKIN & CONNELLY Date /A -5- ()O '~0 VERIFICATION I verify that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: J,-O-OO -~~ '-JVrM_~' _III. ~J ., , r~~ ; .--,.;... ""1l;1~W';l;-T' ~.~,. iS~ r ~ ~ ~ ~ ~ ,..c"ll ". ~ - ~: ~ _ '"'6ol. ~ - ~ ~ ~ Ci (). ~~~ P--~ ~i' o C ;,"''' ~~; ,.;t~. -':;- .~ /'.~ .i >~:~ -~ ..< l::) o ..,., ,.....,...... . , eJ ~ ~ :J ~ ..-~ fli ,.u, ~r '-5 ~, ::;.~ .-_ -.r ;U i-~;Y1 ::::--~ \f? :=J '..0 =< ~ -',-, ~._. ''''' ,'" --"'''. , ~, .- ~ JAMIE L. RICKER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLaND COUNTY, PENNSYLVANIA v. : NO. 2000 - 910 Civil EARL J. RICKER, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF DAUPHIN AND NOW, this ~ day Of~ 2000 personally appeared before me, a Notary Public in and for the State and County aforementioned, Jarad W. Handehnan, Esquire, being duly sworn according to law, deposes and says that a copy of the Complaint in Divorce in the above-captioned action was personally served on the Defendant, Earl J. Ricker, on February 16, 2000 at the Cumberland County Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. ~~~. Jarad W. Handehnan, Esquire Sworn to fu"1d Subscribed to before me this J/.rl:! day Notarial Seal StephIInle L GefIey, ~ Public :==.=== Member, PennSy\VllIlilI AssoCIetkln cI Notaries , ". '-;';"--'h_""'>-;"+_ ~ ,,-,,' , C', ~'.- " "",PH',,"",',,, .... " , lj(--;.~ tnrl' ""----.... :::.:-::.!_-- S?;-{= ~C= 2:>:~ j;:-~:;O ~- , -,- c' C~ =< . o C> ~ ,n -:.~':; ~~".) -'".:; .;..-=> l'\,? " ~- ,= ~ ~ .' ' -~ ' -" J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMIE L. RICKER, Plaintiff : No. 2000-910 Civil Term v. EARL J. RICKER, : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 16, 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 fmal decree of divorce after service of notice of intention to request entry ofthe decree. I veri:fY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. [)jL~/() I Date ~j~ ,(, E L. RICKER ,c"-, "_~,_-:J- .. ,', ~L--"llIil' l"'lU..i>!! ~\lii~ ","".' ,- ."''''--'''-<~ ~ " ~ 0 C> C cr: ;C' ." :?5:i fdr'" r-q -..- z' . CO ~~-l 2:(' r'.) .. (/) --' ,,' ~i~::: r-.., ,~ -0 '(l, >C'" .--'-- -T--; ~('" 2.; (') )'"(,,; ry j-,--; Z > --I 1'0 --' :rJ ~ -<": .-, , . '. . ,^> .' 'oj':,. ~ -.--' '-~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMIE L. RICKER, Plaintiff : No. 2000-910 Civil Term v. EARL J. RICKER, : IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST 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 concerning 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 Mfidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. {)j~/o \ Date 1fJ~ 1 ~/I AMIE L. RICKER --~ ,-~-~~ ~"'_.... ~ ,"' -. '{ i!llIidilld~llln'""- - ~- III' ~b-._ ~. o S ~ -oCCi mfT~ Z:JJ ZC~ (,0.,!.::, -<.< r:.:C' :::;:::;(--' "'7,0..( 3;:2:~ ~ -< .~ .....~" ...- <:) LJ .1 --.:J :'-0 '~~:S ~:-,i~~) :-]~~: :"..-J ::;:2 j.1 ~, .." If" c,:J ~V " 3, r:;> !'" :,- . ~ ,~ ..:. " .~ ~ 'K. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMIE L. RICKER, Plaintiff : No. 2000-910 Civil Term v. EARL J. RICKER, : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 16,2000. 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. Section 4904 relating to unsworn falsification to authorities. ~/~/81 D te . - ..~llIkiil.jr ~... ~i''''"''- ,.....-'-"""'.'. ~<-.-"f" ,- ~ rf~lllll-. o c s: -er['.: nlr-;-' f~~::. ~~~I ~...... ,-~.. :;!?-:c;; L.. ,~, --,,---, >C::. '7 :t C::'l -., -'--4 " ;:'):J r.,..) 'CD -,-.. ",'- ,.,. ,1 ~,;;1 .~.:; -:J,..;. -<., . ,.~~ ~~, ~ > I .ho",",d. ,. ,~-'~ : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMIE L. RICKER, Plaintiff : No. 2000-910 Civil Term v. EARL J. RICKER, : IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REODEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DNORCE CODE I. I consent to the entry of a final decree of divorce without nonce. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in 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. Section 4904 relating to unsworn falsification to authorities. ll.f/l ate - '_I" " il:lIIl~"';'"' r-"1lllill ~= :...,\~ 11'"1"11''''"''''' .~ ....,"" "'.. - o c <" ~~R 0~ ~~- ~s: """ ~,.......--, z(~) >s; :-~ -< M:l~W.i - ~. ',I C:1 -" , , ;::::;l f',) 0'.:> -":::! :J< :..~) Ul ..-: ~ ' h, ~-w= ~ ~ .. ,. , JAMIE L. RICKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 00-910 CIVIL TERM . . . EARL J. RICKER, : CIVIL ACTION - LAW Defendant/Petitioner : IN CUSTODY ORDER OF COURT AND NCII1, this -"2/L- day of <.\UV\Q consideration of the attached Custody Conciliation Report, and directed as follows: , 2000, upon it is ordered 1. The parties shall submit themselves and their Child to a custody evaluation to be peJ:'formed by Stanley SchneideJ:', PhD., for the purpose of obtaining professional recommendations with respect to custody arrangements which will best serve the interests of the Child. The parties shall sign any authorizations, deemed necessary by the evaluator, to obtain additional information concerning either the parties or the Child. The parties shall cooperate in scheduling and completing the evaluation sessions in a timely manner. 2. Pending fUJ:'ther Order of Court or agreement of the parties, the Mother shall have pdmary physical custody of the Child. The Father shall have periods of supervised visitation with the Child, at least bi-weekly or as otherwise directed by the Y.W.C.A., or other facility selected by agreement of the parties. The specific times and dates for visitation shall be arranged by agreement of the parties and the supervising facility or person. The paJ:'ties shall cooperate in scheduling periodS of supervised visitation under this provision in a timely manner. 3. within 60 days of completion of the custody evaluation, in the event the parties aJ:'e not able to reach an agreement as to ongoing custody arrangements, counsel for either party may contact the Conciliator to schedule an additional Custody Conciliation Conference. BY THE COURT, ( ~{Yb1l t -:;;). - O(J RK cc: John J. Connelly, Jr., Esquire - Counsel for Mother Marlin R. McCaleb, Esquire - Counsel for Father p ~ _d, ~" ,,~ - ,,,,,!, " - ~ ,-, -,~, l' ,- .. ",^",e." lif'} /J. 1..!J..Jt;f/.::/r)"" ' .,,- ~ i~ /' '~ ',', i ii 2: L, r; '" C~t j'~4,--,..,._, '-".11';1-,"" Pb7vk,~;i~, ~\l~?Utvrv It ",I ,-~ _.. .."""",.,,,..,~RI'lIl~ :JIIRm. ~",., -" '. ,~~~~ J l' '" ~~I I "" -, ,,",,,-~ .. ~, " JAMIE L. RICKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . NO. 00-910 CIVIL TERM . . . EARL J. RICKER, : CIVIL ACTION - LAW Defendant/Petitioner : IN CUSTODY CUSTODY ca<lCILIATI<l.'I SUMMARY REPCRr IN ACCDIDANCE WITH CUMBElU.AND COON'l.'Y RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRElIlTLY IN CUSTODY OF Erikia Lynn Rider December 28, 1998 Mother 2. A Custody COnciliation Conference was held on May 30, 2000, with the following individuals in attendance: The Mother, Jamie L. Ricker, with her counsel, John J. Connelly, Jr., Esquire, and the Father, Earl J. Ricker, with his counsel, Marlin R. McCaleb, Esquire. 3. The parties agreed at the COnference generally to have a custody evaluation performed if they were able to make arrangements for the evaluation within their financial constraints. It was agreed that the Report and Order in this matter would be held pending notification from counsel as to whether it was possible to have the evaluation done at a reduced rate. The Conciliator was advised by counsel on June 16 that the parties have agreed to entry of an Order in the form as attached. ~ ~ I ..::v,q(') Date ~ Dawn S. Sunday, Esquir~ Custody Conciliator JAMIE L. RICKER, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 910 CIVIL TERM EARL J. RICKER, Defendant/Petitioner CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT fo+L AND NOW, this _ day of /l",. J , 2000, upon consideration of the attached Motion, it is hereby directed that the parties and their respective counsel appear before DIfWN <;. )uNi)AY: 2"'r' ,the Conciliator, at ,3q I/J lviII/A) sr, /v(EC/.fAIUICC,6uUI (fA on the ~ day of ~ " 2000, at q"M, --..tt.M., for Pre- Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. 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 Telephone: (717) 249-3166 LAW OFFICES AMERICANS WITH DISABILITIES ACT OF 1990 MARLIN R. McCALEB The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. FOR THE COURT: By: LAW OFFICES MARLIN R. McCALEB -2- -, .- ~.~"-" ,,-I'" \~,.;~ ,.,,...-r. ,'1,,::c("!:= \. ~'r ,\ ,v~. v ~~~~'.,;:'r".,(~)\.\r:::NO\P.R I N" 2' ') n nO ,r';) \ \ (;'\ "..~ u- }\f 1\ .. ,", ~,~(,; \} rr{ 0\ \"_,('::/::~-"\\ j..,,,\L) \j,J'Jo\ v\,J\-I\;::":;~\N-\C:V\ \IP-.N\l\ \"'C\"{ ,-.ol_" '1'II&~ t$I~~.~d;4 7~ '-/-If~;j ~.~z, 4 ~ -0/I'CJ/ (~,M&.w -z?; 4 ~ i,.". .....,..,.,,'. '."",.",', p-~ .,-,.- ~." - . ~ ,-. _ ~.,.,~"," __.!lJI!III .,.. 't - ~~_.. JAMIE L. RICKER, plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 910 CIVIL TERM EARL J. RICKER, Defendant/Petitioner CIVIL ACTION - LAW IN DIVORCE MOTION FOR ASSIGNMENT TO CUSTODY CONCILIATOR AND NOW, comes the Defendant/Petitioner herein, EARL J. RICKER, by and through his attorney, Marlin R. McCaleb, Esquire, and respectfully represents as follows: 1. That EARL J. RICKER is the Defendant in the above- captioned action in divorce. 2. That a petition for Partial Custody was filed by him this date to the above docket number, which Petition sets forth his claim for partial physical custody of the minor child, ERIKIA LYNN RICKER. A true copy of said Petition is attached hereto and made a part hereof, marked Exhibit "A." 3. That petitioner desires to resolve the custody issue through a Pre-Hearing Conciliation Conference. WHEREFORE, petitioner respectfully moves your Honorable Court to assign this matter to a Custody Conciliator and to schedule a Pre-Hearing Conciliation Conference as provided in the Cumberland County Local Rules. Date: April 5, 2000 ~ Marlin R. McCaleb Attorney for Petitioner LAW OFFICES MARLIN R. McCALEB JAMIE L. RICKER, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 910 CIVIL TERM EARL J. RICKER, Defendant/Petitioner CIVIL ACTION - LAW IN DIVORCE PETITION FOR PARTIAL CUSTODY AND NOW, comes the Petitioner, EARL J. RICKER, by his attorney, Marlin R. McCaleb, Esquire, and pursuant to Pa.R.C.P. 1920.15(b) requests the following relief: 1. The Petitioner/Defendant herein is EARL J. RICKER, residing at 5 Crestview Village, Middletown (Londonderry Township), Dauphin County, Pennsylvania. 2. The Respondent/Plaintiff herein is JAMIE L. RICKER, residing at 9 North High Street, Shiremanstown, Cumberland County, Pennsylvania. 3. The Petitioner seeks partial custody of the following child: Name Present Residence Aoe Erikia Lynn Ricker 9 North High Street Shiremanstown Pennsylvania 1 year The child was not born out of wedlock. The child is presently in the physical custody of the Respondent at the residence set forth in paragraph 2, above. During the past five years, or since her birth, the child has resided with the following persons and at the LAW OFFICES ~RLIN R. McCALEB following addresses: EXHIBIT "A" Persons Addresses Dates Jamie L. Ricker Mildred Kaiser 9 North High Street Shiremanstown Pennsylvania 12/28/98 to date The mother of the child is Jamie L. Ricker, currently residing at 9 North High Street, Shiremanstown, Cumberland County, Pennsylvania. She is married to the Petitioner, Earl J. Ricker. The father of the child is Earl J. Ricker, currently residing at 5 Crestview Village, Middletown, (Londonderry Township), Dauphin County, Pennsylvania. He is married to the Respondent, Jamie L. Ricker. 4. The relationship of the Respondent to the child is that of natural mother. The Plaintiff currently resides with the following persons: Name Relationship Mildred Kaiser Mother 5. The relationship of the Petitioner to the child is that of natural father. The Petitioner currently resides with the following persons: Name Relationship None None 6. Petitioner has not participated as a party or witness or in any other capacity in other litigation concerning the child in this or another court. LAW OFFICES ,RUN R. McCALEB Petitioner has no information of any other custody -2- , proceedings concerning the child pending in a court in this Commonwealth. Petitioner does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) Petitioner is a fit and suitable custodian for the child. (b) Petitioner desires to maintain a close and loving relationship with the child. (c) It is in the best interests of the child to maintain a close relationship with her father, the Petitioner. 8. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. WHEREFORE, Petitioner requests the Court to order that the parties share legal custody and to grant him partial physical custody of said child. ~~ Marlin R. McCaleb Attorney I.D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, PA 17055 (717) 691-7770 FAX: (717) 691-7772 Attorney for Petitioner LAW OFFICES RuN R. McCALEB I verify that the statements made in this Petition are true -3- LAW OFFICES ~LIN R. McCALEB - and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S., Section 4904, relating to unsworn Date: 1.//6' falsification. A~ . Eae;::Y J. Ricker- , 2000 -4- t2 ill ~ tn Z ~; 3< ~..., U.J~", - (z ~,~9 .,- 0..:;;"( ""- 1)...,..;- ~ c~3 C);-=-, 1j"J '~;fn 2;,~-:~ I .~~lZ L,-_,L- "'~'Z .......--',. , cc tJ]LU Lt... ,.-- Cl.._ l~fJD- F.~ G. ::~ ~_L 0 :::> C) 0 0 r ~ e< 0 H Z , <:fl~ +' ~ ~:> '" (j) 0 r<1 H (j) '" 8 ~ ~ H >< :>: '0 0 ~ 0 o..<:fl p=: '" ..., 8 ~ Z r<1 0 +' Z p=: , ~ Z Z 8 0. ..., r<1 0 w ~ 0r<1 Ul +' :>:8 ~ w z ~ 0.. H (j) (j) Z~ w :i .J oc o .J H p=: 0.. " H ~ ~ l;; w '" >- 0 , :>::J: "'- "'- H H u oc N ~ U>< H<I: 4-< +' <:flH ii: w z z " ;; x z 8 UH -4-< . '" <:flU IL ~ ow 0 oc ::; ~ Z p=:..., Ul - <<J <I:Z w " ~ 0 ~ 0 I r<1 +' :> p=:'O 0 ~ " ~ . . w Vl 0 " 0 rl ~ '" r<1 '" P=:U .J ~ ~ <C 0.: D:: 8 U o-,Z U..., ~ (j) 0 z w ~ ~ " p=: 0 H <<J U4-< Ii< >< oc m ~ ~Cl I Hr<1 P=:rl H (j) Cl IL N ~ OZ 8U 0.. P=:Cl ZO z U <I: OUP=: . 08 ~ I H O~O H . H<:fl u r<1 P=: 0 :> ':> 8~ w iI1 r<1 NH H r<1 OU ::; 8 I:Q H Cl H H :>: :>: .:> ~ P=: Z~ OHZ <I: H U ZUH ':> r<1 . . APR .' 7 2n,) , . JAMIE L. RICKER, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 910 CIVIL TERM EARL J. RICKER, Defendant/Petitioner CIVIL ACTION - LAW IN DIVORCE PETITION FOR PARTIAL CUSTODY AND NOW, comes the Petitioner, EARL J. RICKER, by his attorney, Marlin R. McCaleb, Esquire, and pursuant to Pa.R.C.P. 1920.15(b) requests the following relief: 1. The Petitioner/Defendant herein is EARL J. RICKER, residing at 5 Crestview Village, Middletown (Londonderry Township), Dauphin County, Pennsylvania. 2. The Respondent/Plaintiff herein is JAMIE L. RICKER, residing at 9 North High Street, Shiremanstown, Cumberland County, Pennsylvania. 3. The Petitioner seeks partial custody of the following child: Name Present Residence Aqe Erikia Lynn Ricker 9 North High Street Shiremanstown Pennsylvania 1 year The child was not born out of wedlock. The child is presently in the physical custody of the Respondent at the residence set forth in Paragraph 2, above. During the past five years, or since her birth, the child has resided with the following persons and at the LAW OFFICES MARLIN R. McCALEB following addresses: ',<, Persons Addresses Dates Jamie L. Ricker Mildred Kaiser 9 North High Street Shiremanstown Pennsylvania 12/28/98 to date The mother of the child is Jamie L. Ricker, currently residing at 9 North High Street, Shiremanstown, Cumberland County, Pennsylvania. She is married to the Petitioner, Earl J. Ricker. The father of the child is Earl J. Ricker, currently residing at 5 Crestview Village, Middletown, (Londonderry Township), Dauphin County, Pennsylvania. He is married to the Respondent, Jamie L. Ricker. 4. The relationship of the Respondent to the child is that of natural mother. The Plaintiff currently resides with the following persons: Name RelationshiD Mildred Kaiser Mother 5. The relationship of the Petitioner to the child is that of natural father. The Petitioner currently resides with the following persons: Name RelationshiD None None 6. Petitioner has not participated as a party or witness or in any other capacity in other litigation concerning the child in this or another court. LAW OFFICES MARLIN R. McCALEB petitioner has no information of any other custody -2- proceedings concerning the child pending in a court in this Commonwealth. Petitioner does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) Petitioner is a fit and suitable custodian for the child. (b) petitioner desires to maintain a close and loving relationship with the child. (c) It is in the best interests of the child to maintain a close relationship with her father, the petitioner. 8. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as parties to this action. WHEREFORE, Petitioner requests the Court to order that the parties share legal custody and to grant him partial physical custody of said child. ~~ Marlin R. McCaleb Attorney I.D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, PA 17055 (717) 69.1-7770 FAX: (717) 691-7772 Attorney for Petitioner LAW OFFICES MARLIN R. McCALEB I verify that the statements made in this Petition are true -3- LAW OFFICES MARLIN R. McCALEB .... . and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S., Section 4904, relating to unsworn Date: 1/=>' falsification. ~~ Eap' J. Ricker- , 2000 -4- " ~, CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Petition for Partial Custody was served upon the Plaintiff herein, or her attorney, on AjJ,.;1 f , 2000, by I ii !~ ,~ "I i " i\: j \! I 'j Ij I Ii,,!.' i, I: I; I I I I l I depositing same in the mail at the United States Post Office at Mechanicsburg, Pennsylvania, postage prepaid, properly addressed as follows: John J. Connelly, Jr., Esquire James, Smith, Durkin & Connelly, LLP P.O. Box 650 Hershey, PA 17033-0650 LAW OFFICES MARLIN R. McCALEB >- to ~ tx; 1.,"0 <1- 1,,-- ?><'C tU~"? .::lz s:(:~;, .","~ C)< (~.: ..,;.- " -- .-,0: ';;~ r',r-- :6?' U'1 ~5~ LU'.'. :..-cZ [~ ~ C,,: ~H'B: 0.. """ ..2 N lL 0 :::J 0 0 () ~ ~ 0 H Z :>< (1).0: 0 .o:~ -I-' l-< 0 m Ii1H !': Q) 8 m H:>< :>: Q) !': (I) ~ 0 ~(I) p:; 'd 0 ::> !:: Z Ii1 !': .... U ~ ZZ 8 0 -I-' OJ ~ z 01i1 0. .... H u OJ ~ " OJ ~~ H Ul -I-' .0: .J oc o .J H Q) Q) H m ~ ~ OJ m '" >- 0 - ~:;s: p:; ~ 8 u oc N '" OJ Z z U:>< H.o: "- . "- p:; u: " ~ x z 8 UH -<+< Ul -I-' .0: IL ~ oc o OJ ~Z p:;<+< :> - !': ~ 0 OJ ~ m ~ ~ m ~ d 0 0::> 01 1i1.... p:; CO OJ '" .OC 0 M ~-I-' 1i1'd p:; .J ~ ~ " ~ :J 8U ",Z U !': ~ !': 0 z OJ m p:; 0 H.rl UQ) Ii. " '" '" oc N u ::>0 I HIi1 p:; CO H<+< ~ Z OZ 8U .-< P:; Q) Z " U.o: o UP:; .~ 0 0 ~ H oC:::O H . H u OJ 1i1P:; o ~ t-:l 8 ~ iI11i1 NHH Ii1 H 81Il HO H H 8 :>: .~ ~ ~ Ii1 Z::> OHZ ~ HU ZUH t-:l Ii1 . , " '-,'. t ., " ,,, ' - ~ JAMIE L. RICKER, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 910 CIVIL TERM EARL J. RICKER, Defendant/Petitioner CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow EARL J. RICKER, Defendant/petitioner, to proceed in forma pauperis. I, Marlin R. McCaleb, Attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Date: A_ j__ ~ a ,2000. Marlin R. McCaleb Attorney for Defendant/Petitioner LAW OFFICES MARLIN R. McCALEB LAW OFFICES MARLIN R. McCALEB J~ JAMIE L. RICKER, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 910 CIVIL TERM EARL J. RICKER, Defendant/Petitioner CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the Petitioner in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name:Fox/ T K'c..~ Address: ,-:; tresNlew tIt/ICAJe. ;t!dd4.lown fb. /70!5"l J 178J-IRO-7?d}- Social Security Number: (b) If you are presently employed, state: ~ Employer: /Ylc.. frorntJ~MS Address: /0/ ;1/ (!c.mero/1 sf. f/a.rns.?'l/r5 Pet /7/,,/ Salary or wages: '!zoO a w-u...K Type of work: Odv(.Y'-hS! n S If you are presently unemployed, state: ~/A Date of last employment: n/~ , Salary or wages per month: n/tT (c) Other income within the past twelve months: n~/-1 Business or profession: ~/fi Other self-employment: hJ~ Interest: n/14 Di vidends: Ii) Il Pension and annuities;~~ Social Security benefits: n;l~ Support payments: nJ ~ Disabili ty payments: 11/ fl' Unemployment compensation and supplemental benefits: njl'r Workman's compensation: A/~ Public Assistance: ~/ft Other: (d) Other contributions to household support: (Wife) (Husband) Name: ~~ If your (husband) (wife) is employed, state: J?~ Employer: Eb5 Salary or wages per month: 8,SVh,e Type of work: 9a le.s Contributions from children: ~/~ Other contributions: AJfi te) Property owned: Cash: (JIll LAW OFFICES Checking account: _ ,,c rrV $ ~. MARLIN R. McCALEB -2- -0- II __,-" , ..---. . ,-,~ -0 ,". Savings account: $ 1"7/1"" , Certificates of Deposit: h~j4 Real estate (including home) :~~p Motor vehicle: Make l1/ft Year I Cost Stocks; bonds: A/~ Other: I'-/fr Amount Owed (f) Debts and obligations: Mortgage: rI) f4' Rent: J501YlMtt- Loans: flJ'" Other: Payment Arrangements; (g) Persons dependent upon you for support: (Wife) (Husband) Name: Children, if any: Name: En KJ '" LJ"'Y1 ((/{;'/UH" Name: Other persons: Name: Relationship: 4. I understand that I have a continuing obligation to inform the Court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. LAW OFFICES MARLIN R. McCALEB 5. I verify that the statements made in this Affidavit -3- LAW OFFICES MARLIN R. McCALEB ....", .",>' .;, .,' ". are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: <(/5' ~~4~~ , 2000. -4- ~-- CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Praecipe to Proceed in Forma Pauperis was served upon the Plaintiff/Respondent herein, or his attorney, on A/I ,~ ~. v , 2000, by depositing same in the mail at the United States Post Office at Mechanicsburg, Pennsylvania, postage prepaid, properly addressed as follows: John J. Connelly, Jr., Esquire James, Smith, Durkin & Connelly, LLP P.O. Box 650 Hershey, PA 17033-0650 .~ Marlin R. McCaleb LAW OFFICES MARLIN R. McCALEB >- CY: <C ~.J~~ C) ~~.:: C~.."' 1.J_ .J, r~L, r~-,'- J..r"', G-: ij} I c:::: C.. "'" o o ~ '7 ::::J .".)<C C-=7 +:J~ .......>. \::::; ;:J --"0 :5:z ,-I'~Z ;:LJUJ cpo- .> 5 <.) If) u-;, """ r...~ OH Z Ul~ ~:> ~ 1"1..:1 +J " ~ ..:1:>< :>: <:: (]) ~ 0 P<Ul ~ (]) <:: ~ Z 1"1 '0 0 0 ~ ZZ 8 <:: .... 1"1 w ~ z 01"1 0 +J I"1Ul u w ~ 4 w ~P< ..:1 0. .... UH .J OC o .J H Ul +' O~ Vl ~ ~ ~ > w OC Vl 0 - :>~ (]) (]) ~1"1 u N Vl W Z z U:>< H~ ~ . P< P<P< u: lJ - >< z 8 U..:1 -"- Ul "- P .. ~ a: <l: 0 W 0 lJJ ::!: m 0.. r...Z ~4-l :> -+J O~ ~ mI-' . OP 01 1"14-l ~ <:: 8P< UJ lfl 0 lJ 0 M ~.... 1"1 l<l .J ~ ::c: <{ a: a: 8U "'Z U+' ~'O ~~ z W :J <{ 01 ~ ~ 0 H <:: U <:: oc.. u PO 1 HI"1 ~.... H (]) H~ LL. N Z OZ 8U l<l ~4-l UO 4 U": OU~ 'M (]) 1"1r... J: ..:1 O~O ..:1P< '0 ..: u w 1"1~ o :> t-:J ~ ~ ttil"1 N..:1H 1"1 P< 8i1l HO H ..:1 :>: .:> ~ ~ ZP OHZ ~ HU ZUH t-:J 1"1 LL o > AP,R- 7 ?OO~ ,~ c--' . ~ ,~" -. ~ ,.;.. ,~;"",<;;"~,~,;",'"",;,,--",,,_fx . '~' ". , "1. I , JAMIE L. RICKER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA : NO. ~tX>- 9(t;) G;.;,,{ T~ : CML ACTION - LAW : IN DIVORCE EARL 1. RICKER, Defendant Jamie L. Ricker - Social Security No. 191-68-4984 Earl J. Ricker- Social Security No. 176-60-7441 L_ IIIii i.' ,i.,"". k.c. .,~~'"~ .' ,.. ... < . ~- ,~, ~.. ;.., - -~, h \ .,' ,. > "." "e,"""." i> t -0 C~~- r;',{ .......~ .-. ;:::" (n,:J:' ~<,/ ~~:~--' );;2= '- ~ (') c: ~. t.D a o '", :~'q '~"-'j n :"h ,'"' r::O:::~ ;:.1:1 ~~J ~2 '~5,;~J " c J ~ n-j ~_J ;.;:i :;'7 -<; G\ ~;: l0 !If <~ " .~ ~, . ~ . ~ - A' "ni, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW JAMIE L. RICKER, Plaintiff : No. 2000-910 Civil Term v. EARL J. RICKER, : IN DIVORCE Defendant PRAECIPE TO WITHDRAW APPEARANCE To the Prothonotary: Please withdraw my appearance as counsel for Plaintiff in the above action in Divorce. PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance as counsel for Plaintiff in the above action in Divorce. Respectfully submitted: Maryann urphy, Esquire MidPenn Legal SerVices 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 ,01 ~~-""~'" -, 1ilIil~~~" ~. ...~ - ""~ ;a.-.ii,-~rn;;lf~::lliM;jj!'." 1LS......liii " () CJ- C) C 1 <: ..,., -r-'l[': r'1 n'1rT, C:JCJ ~e~' f'->o.J ~7: r:I"" .- '-~ v ~~~ 1'0 /.::.. -j CO -,- " ~ ~ ~~ ~ -~ " ~ '",' -<. iIii:{!, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JAMIE L. RICKER, Plaintiff : No. 2000-910 Civil Term v. EARL J. RICKER, : IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in Divorce on the 12th day of March, 2001, hereby elects to resume the prior surname ofJamie L. Kaiser, and gives this written notice pursuant to the provisions of 54 P.S. Section 704. Date: 4/ J3.} 0 I bia -J. ~~ (jIAMIE 1. RICKER bo, i.. ~~XJn/ IE 1. KAISER COMMONWEALTH OF PENNSYLVANIA: : ss: COUNTY OF CUMBERLAND On the /? fJ...- day of AI''' r ,2001, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and 0 Notary B blic NOTARIAL SEAL ROBERT J. GOLD, Notary Public Hampden Twp. Cumberland Counly My Commission &pkes July 10,2003 IIiIrli..~ -,'.. ,'. :iliB ~W' ~1tlfiID[ [1 _ ,,~ ",~ ~',"",'_U ~. 1m frr'_Jilli>lti~~~ 'I. 'J ...... ~ ba ~ ....' . ""'"'"' ~ tt --.. ....... -- ~ <\:' "'<:l ~."".'" '" -'~.~ Iiii ~ <:). o ~ ~ '" ~ V> .J-' ~ ('>' ?':- '"" ,1 o C ? .., -cJfD 1"11[1::., 2..,l,' Zr;:. ~":::-- r:C'~' '<: " ~O "",0 ,.,....C ~ ~ .s ",,' - o o -i"l ~ ."" :.< :'!J F co 1 \.~:; " ,',\ ] .~-S ~.f{ ~~ ~ :JS -< ~ ;..) CO