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Home My WebLink About00-01276 '-:[. -" -. :I: :1:;1;:1: :I: ;I;:I:~:I:;I;:I: ~;I;:I::I::I::I:~;I;:I: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . LARRY J. BANNON, Plaintiff No. 2000-1276 CIVIL VERSUS MARGARET ANN BANNON, Defendant . DECREE IN DIVORCE . AND NOW, 2002, IT IS ORDERED AND \5 DECREED THAT LARRY J. BANNON , PLAINTIFF, AND MARGARET ANN BANNON , 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 BE:EN ENTERED; NONE . . . . . . . . . . , ~ ~~ ~ ~~~ ~~ ~ ~~ ~ ~ ~ ~ . . ~~~~ . ~'-' .r, .. . . . . . . . . . . . , . , . . . , , . . , , . , . . . . . . . . . . , , , , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . "'~~1iiWiiI - 'iiIIJi; "-'=' "' Y,--",." mn _.' '"'''.._'' .... _,,,._ ,~,," _ _0, .,,"-~ ~.....- 7/5'0':<' 7. /s-.c c:> M . "~- IIil;'J ,\.. -. ~"\ " ~ , &:1 [1~ ~~~ ~ ~ '11~/U~~~. III LARRY J. BANNON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000- 1276 CIVIL TERM MARGARET ANN BANNON, DEFENDANT IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 (d) (1) of the Divorce Code. 2. Date and manner of service of the complaint: u.s. Mail, Restricted Delivery, March 10, 2000. 3. (a) (1) Date of execution of the affidavit required by section 330l(d) of the Divorce Code: February 28, 2002; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on April 30, 2002, served on April 25, 2002. 4 . Related claims pending: None 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: u.s. Mail, May 20, 2002. ~-\b.~ Thomas D. Gould Attorney for Plaintiff -0_, - _,~ ;_, _ ,of "-_:"'"_" " , III .' ~. ~.- '-'- ........., ., ,. .. -^, o C -o~ nl r-~-. """"'7--', .~ L:'~' cn/:' ~C. ::r; -', ~~i -.:-'" =J ", -~- ,_ .. _~w._" . c:::> 1'.) '--- c:: r I """, "'"tJ o '~n .-j :~~~ -;::) t!J '~~~ SiiT; dO ::< ~) 'f';.) ",~~I . II. .,J, ~". ,", ~~,,,,,,~'__~"""_"_ ,~.III_iJll!llIlIIl'lI!m'5 ~ ,. )('0. " ,,, 'ijj '" OJ I~ " :t . ~ " =' c o " ~ ;;, E o .. SENDER:,' CI C~mp[etelifem~ 1 and/or 2 for additional services. Complete items 3, 4a, and 4b. C Print your name and address on the reVBl'$e of this form so that we can return this card to you, o Attach this form to the front of the mailpiece, or on th~_aC\<.,jt:space does not permit." >,;C__ - [) Write 'Rawm Receipt Requested" on the manPiecif., ,"Q,w,1t!~.e,J:l,rticle number. [J The Return Receipt will show to whom the article w ' li'l~r!'!.d and the date deliverej:!; - ,;';,.', '>.' , 3. Article Addressed to: 48. Article Number fV/fllJ'VJ4'.t..f- jJ'lJ(IJ t:>/U1""! 43ervice~:e 91'1 S' 30 I ~1't gyA.c.c.w t. IlVe.fll.l 0 Registered. '1'1 0 Express Mall CltvelAYld, Off I./VlIO 0 RetumReceiptforMerchandi.e I alS0 wiswto re<<eive the follow~ ing services (for art exlra fee): 1. 2. )(, Restricted Delivery ~ertlfied o Insured oeOD ~ -\ ;,- j 11 1\ ;'.:" 1(j2595.9~H\-o223 Domestic Return Receipt _I'" _r" I" ~o 1i .~ " III ~ l:L 'il " II: c !l &1 g> .~ .e " g, . '" c .. ;: LARRY J. BANNON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 1276 CIVIL TERM MARGARET ANN BANNON, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail, certified, restricted delivery, on March 7, 2000, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the postal return receipt attached hereto, the Complaint was received by the Defendant on March 10, 2000. ~44Q. 44 Thomas D. Gould 10 # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 .. . h ,- ~,,". '<:'--"'" ,"_ i . '_'2' '" I"r ~] , ?"-"-"--,~ ' - ~ ' > o=J,,~..~,__,~_ r'~' ,--" ',,' - ~.~ ~ c:> , > 0 C r~! --1'1 $: ;:::: u n~l no' ~.y~ - , ~-, Z ~~~ ; ~Q oT\ r""::l (-:) X r.:::C-;' L' :'?2i )>~~ :~. ~~~~ 5g .~, ,) Z ~ =<! OJ' :n -< . "~ ,"~'_ " ,~...-.,,~.~ tl!m!lMl!l!!I_I!Il~!!JIlIIli'! .. LARRY J. BANNON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBEMJ\ND COUNTY, PENNSYLVANIA v. NO. 2000- 1276 CIVIL TERM MARGARET ANN BANNON, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that Plaintiff's Notice of Intention To Request Entry of Divorce Decree and Defendant's Counter-Affidavit Under Section 3301(d) of the Divorce Code was served upon the Defendant by depositing the same in the United States mail, first class, postage pre-paid on May 20, 2002, to the address at which defendant received the complaint in divorce. The envelope was not returned by the postal authorities. ~Q4().~ Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 '-," - ~. I .. r c LAlUI.Y J. BANNON, PLAINTIFF IN THE COURT OF COHMON PLEAS COMBE1U.AND COUNTY, PENNSYLVANYA : v. NO. 2000- 1276 CIVIL TERM lomRGARET ANN BANNON, DEFENDANT . . IN DIVORCE . . NOTICE OF IN'rENTION TO REQUEST EN'rP.Y OF DIVORCE DECREE TO: MARGARET ANN BANNON .: ~?\-~-.i;-i:,,;:J.::_.:~.~;~j-._t.._;;._~:.:.j_~_,:_;..':_:~_..c_~~~-=_-:.-_~.:_~;~.~.,_-~-.,.~..c~.-::--__~.:.'.~_:.._i:.'~..~.-.c_:.;:.-.~.:'~.'.:.=_.~~_i:.~;_~;'.:;_~_:;.__:.~_"_'..._...__'_; i -- - , '. _ ..' .. - '-- - -, - _,_ ___ -- - <>:;'".:<;":,?-~ ~r,;:";:';:-;:.'.~-<,,:_~:;-~L_ ~-::-:::_;_'-;=- '_:t~~~;:...'---.~'.c-:. ~::.~, _~.,:~::;~.:.,.,..[-~;:_-;,..: 0:--'- "- You have been sued in 'an action . for divorC<iL' You have- failed to answer the complaint or file a counter-affidavit. Therefore, on or after June 10, 2002, the plaintiff 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 final decree in divorce. 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. YOU SHOULD TAKE THIS ~A~ER 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 HEL~. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 " rp'._~ ~ ,__",0'"_ ,-, -.-.,,',' . - '1 -_....- j. ....t..: ./.:,,-:, . '-:::,;~';";";;?;'f'~":"8@?~;';~'f:~~~ ... (' c LARRY J. BJUtNON, PLAINTiFF : IN THE COURT OF COMMON PLEAS CUMBEmJ\ND COUNTY, PENNSYLVJl.NIA : v. : NO. 2000- 1276 CIVIL TERM MARGARET ANN BANNON, DEFENDANT IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT ONDER 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), (iil 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 propert;{ ~ lawyer's fe_es or expenses if' I: do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this ~ounter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Fa.C.S. 4904 relating to unsworn falsification to authorities. Date: MARGARET ANN BJUtNON ..,.-..-....-_.,_._~...__..'""...--~-. , ~. .,_,,,O_',V'__ .0:'__ 'e," .--_~"_ , . _ ',~ _.::.;:.~::,u~~.-.,~ ~ ___I'~ . .: .., " -"-~ -,-", -- .,.. ',_""'-r'~"_ r~'~ "'-', - ,.' ~ ,.. "'., ."~,,,," -~~ .-- ,T. ''!'' ~, "'~ <. "'1 n '" 'V- ,-~ ." '" -o'~ ,.- ~, -~'" ,-,,,~ "",..,-- ~.- -.-. " .- ... , () CJ 0 C ('-",) s: T1 '0 0..1 ~~: rn , - Z -'...~ "--, Z,---- I fTl CrJ ':/.':- r'-.) ~1~ -<~.. ~G ~tJ ~;:C') , . ~T" $:i~ :::-!(~-; :....l ;,:-5 fTI <- :r; :< '0 ::D -< - "",,,,l\I!I~I~~~ LARRY J. BANNON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - /;}7~ IN DIVORCE CIVIL TERM MARGARET ANN BANNON, 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, including custody or visitation of your children. When the ground for is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 ~. ~.-, O_C'~' "." __,~_ ___o' " - ~,~ , ~ LARRY J. BANNON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - JjJ11,- CIVIL TERM MARGARET ANN BANNON, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301 (d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Larry J. Bannon who resides at 4302 Allen Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Margaret Ann Bannon who resides at 18122 Syacuse Ave, Cleveland, OH 44110. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 1, 1980 in Willougby County, Ohio. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. ;,'DTI ~'" . _ ,,~'" _"'0:'. 'co, 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. ~1>.~ Thomas D. Gould , Attorney for Plaintiff I: I: I.D. # 36508 ii ~ 2 East Main Street Ii Shiremanstown, PA 17011 !j !I (717) 731-1461 I' Ii Ii !I I; VERIFICATION Li I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made Ii I'.'.', ! ,I " r:! " I,: I, I " Iii LI 1'1 I subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. ~.~ Larry . annon Date: 03-()(,-oo I I' I Ii I: I: I , i:: i,< Ii I, i"~a~L ~. t'.- ,",'. ~_. . - >- ~ LUS? OC' U- ~....c: '.L. r:~:: c;) (~; 66": LlJG~ --.J'-. w.: ~T'! j;';': LI_ e) @ r- o c;.. :v.: .,z r- I n:: ""'" ::i:; Cl o 1 f>~ ~~8 ~g\B~ ~(()~ --- '-- rb ~ ri o ~.~ ~~ \;F:J ~ ~ z: :::J<( 0- oZ: :"C C)~ "7>- ~:::.:U) ,y:!Z tbZ cog: 2' :'5 (.) , ----'-1'. 0 -l :J 0 0 '" I;j " - ~C) <( W ..J '" if '" I- W ~ (f) ~ 0 z i. EO (f) ;;' '" 1;j ~ (') 0 L " ",([) z l- i- '" (f) z :'\ <( ~ <( <( " w L L <( (\j w '" 0 I (f) I I- . ',;Ml LARRY J. BANNON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000- 1276 CIVIL TERM MARGARET ANN BANNON, DEFENDANT IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): wi (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 if I do not claim them before a divorc~s granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I 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 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: O(~/(J5! OJ.- ~/CJ/uj ~ ~ MARGARET ANN BANNON :;" -".'..,'7" _ -,', ~c,'~," ",,,._..~f-,,:! "i., '" ~ ~7"- -_,-"",,_y .: 1''''(. - -r '-'i-'-"':- ,(-':- ">,1-, ',-H M,_~,__'-"-",.-.,",~" '"'" '"0' . ",""--- -:~_7"f< ou, '" 0 ~ ,. -, ~, ,'~'- --~ ,-- ., ~"""~~ ~, . ~', -. . ~./~"<~_' .~ ~1' <,' ''/'.~ ,"' ',- -, ,~".~- ~ ~ ~ "~-"" c_c <" - ~-,-.",,",' - -IIilli.lcrc'F 8 0 ~ N .,,~ ~ :.-=1 ffirn 2;:0 :".71f!.;! ZC I -orl'1 Cf.l"", -.! '50 ~6 ,- C~ ~R -0 :J! ,., ::;: O::n ;;;:(.,., N ~B ~ .. Om co ~ -< =--~- ~~I~~IIl!P , , LARRY L. BANNON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW MARGARET ANN BANNON, Defendant NO. 2000-1276 CIVIL TERM ORDER OF COURT AND NOW, this $~ay of March, 2000, upon consideration of Defendant's Motion pro Rac Vice, and the motion being incompatible with the requirements of Pennsylvania Bar Admission Rule 301 (requiring, inter alia, that such a motion be made by a member of the Pennsylvania Bar and that the attorney of record in the case be an attorney other than the counsel admitted pro hac vice), the motion is denied, without prejudice to the right to refile the motion through counsel of record in conformity with Rule 301. A COpy ofPa. BA.R. 301 is attached hereto for reference. BY THE COURT, Thomas Gould, Esq. 2 East Main Street Shiremanstown, PA 17011 Attorney for Plaintiff .~ 00 P./ :; r; C? A--~ Margaret Ann Barmon 18122 Syracuse Avenue Cleveland, OR 44110 Defendant r,~J,r_ , ",-p"..'" - --'-"- '. . "", --,"" "."" :""4'^t',- ~ "- , - , ,- ~- ,"~I - ~'~"-~":..c'~-c;~ _ , _ ~iilli- , h ~,.~~_.,. "",. - -~-, -,' .-'W"," - . f\\..lD-OfHCt OF "1\-"- ;.;'ri\L'r:",';Oit<R'i Clu \,\~,R 2.9 \,1'\:',; f! \ ClJMBSRlR.;\j COUN\'{ Pt.NN'2,'1\.~J pS'-l\A. ~~ , ',' '"" , ~ , 1. ", ~'_' Ruth R. Fischbein-Cohen, Esq. 3552 Severn Road #613 Cleveland, OR 44118 :rc -'..',"" . -....,'<. ".~, .< - " , '0,', ,.' Rule 231 BAR ADMISSION RULES (d) Action by Prothonotary. If the motion and related documents are in proper order and the re- quired fee is paid the Prothonotary shall: (1) Enter the name of the applicant upon the docket of persons admitted to the bar of this Commonwealth and the practice of law. Admissions pursuant to Rule 204 (relating to admission of domestic attorneys) or rule 205 (relating to admission of foreign attorneys) shall be by order. (2) Notify the Administrative Office of the admis- sion ofthe attorney. (3) If the requisite fee has been paid therefor, issue an engrossed certificate of admission under seal. (e) Motions in Open Court. An applicant may elect to take the oath of admission in person before the Supreme Court at such time and place as may be directed by the Court. Note Based on former Supreme Court Rule 12B and C. The engrossed certificate of admission has been made optional at additional cost. The text of the oath of office is set forth in 42 Pa.C.S. ~ 2522 (relating to oath of office). Amended effective Jan. 4, 1982: March 13, 1989; Nov. 13. 1991; Oct. 2, 1997. RULE 232. EFFECT OF ADMISSION TO PRACTICE (a) General Rule. Members of the bar of this Commonwealth (see Rule 201 (relating to bar of the Commonwealth of Pennsylvania)) shall be entitled to practice law before every court and district justice of this Commonwealth upon presentation of a current certificate issued by the Court Administrator of Penn- sylvania under Enforcement Rule 219 (relating to periodic assessment of attorneys). In connection with the filing of any legal paper, the notation on the paper of the attorney's current identification number issued by the Court Administrator of Penn-.ylvania shall constitute proof of the right of the attorney to practice in the county in which the paper is filed. (b) Abrogation of Local Requirements. Alllocal rules and practices are hereby abrogated which; (1) Govern the right to practice before any court or district justice of any county or judicial district of this Commonwealth. (2) Require an office, partner, associate or assistant within any county or judicial district in connection with the practice of law. (3) Prescribe any residence requirement in cannee. tion with the practice of law. (4) Limit the number of practicing attorneys in any county or judicial district upon a quota basis. (5) Require advertisement in a newspaper or legal periodical, or any approval, examination, ceremony, certification, or admission, or other similar require~ ments in connection with the practice of law in any county or judicial district. (6) Require the presence in person of an attorney in connection with the filing of any legal paper. Note Based on former Supreme Court Rule 13 and Pa.R.Civ.P. 205.1. SUBCHAPTER C. RESTRICTED PRACTICE OF LAW IN GENERAL RULE 301. ADMISSION PRO HAC VICE (a) General Rule. The provisions of Subchapter B of these rules (relating to admission to the bar gener- ally) do not apply to motions for admission pro hac vice. An attorney, barrister or advocate who is quali- fied to practice in the courts of another state or of any foreign jurisdiction may be specially admitted to the bar of this Commonwealth for purposes limited to a particular matter. He or she shall not, however, thereby be authorized to act as attorney of record. (b) Procedure. In the case of such applicants, the oath s\1a11 not be required and there shall be no fee. Such admissions shall be only on motion of a member of the bar of this Commonwealth. Except as other- wise prescribed by general rule, written notice of such motion shall be signed by such member of the bar, shall recite all relevant facts and shall be filed with the clerk of the court in which or with the district justice before which the matter is pending at least three days prior to the motion. Any court or district justice shall grant such a motion unless good cause for denial shall appear. Note Based on U.S. Supreme Court Rule 6 and former Supreme ',I Court Rule 13 Gast paragraph).' 990 , "'- MAR 2 . 20~ IN THE COURT OF COMMON PLEAS DIVISION OF DIVORCE CUMBERLAND COUNTY, PENNSYLVANIA Larry J. Bannon ) Case No. 2000-1276 civil Plaintiff ) Term v. ) Judge: ) Margaret Ann Bannon ) Defendant ) ) JUDGMENT ENTRY GRANTING ) MOTION PRO HAC VICE For good cause shown this Court grants Margaret Ann Bannon's Motion permitting Ruth Fischbein-Cohen to answer the within complaint, pro hac vice, as counsel for defendant, limited to answering said complaint. IT IS SO ORDERED. Judge Date ~:~ ," . IN THE COURT OF COMMON PLEAS DIVISION OF DIVORCE CUMBERLAND COUNTY, PENNSYLVANIA Larry J. Bannon ) Case No. 2000-1276 civil Plaintiff ) Term v. ) Judge: ) Margaret Ann Bannon ) Motion Pro Hac Vice Defendant * * * * * * * Now comes defendant Margaret Ann Bannon, and pursuant to the Fifth, Sixth, and Fourteenth Amendments of the United States constitution and this Honorable Court's discretionary power, she hereby moves this Honorable Court, for an order that Ruth Fischbein-Cohen, Esq. be permitted to appear before this court, pro hac vice, for the limited purpose of answering the within complaint in divorce, as counsel for defendant Margaret Ann Bannon. In support of this motion, the undersigned states that she is a member of the Ohio Bar, Registration Number 0041968, and in good standing. Authority to grant such permission is implicit in the within Court The undersigned has extensive experience in domestic relations matters in Ohio. If permitted to merely answer the within complaint in this Court on this one time basis, pro hoc vice, defendant will procure Pennsylvania counsel for future court appearance, matters, and procedures. The wi thin complaint must be answered wi thin a short time and time is of essence. Once this Complaint is answered Margaret Ann Bannon will have sufficient time to retain a Pennsylvania lawyer. '"'''1!ll!''iII ~ 'I ... -\ ,'~,~ ... Therefore, for the aforestated reasons, I believe that justice would be served if I were allowed to answer the within complaint for Margaret Ann Bannon. A Thomas 170.11, // /", /"" <-"",,?" /-"",,- Respect~!l'l"iy,..s'~bmi tted, .' /'.. ..;;...---' .... /.... ".~'"" /,., .,,_..,e../-:>--' / -COHEN Bannon SERVICE /~ copy of the foregoing l"!otion has bee;n/ser~ upon Gould, ESli' 2 East Ma1.n Street,' S1].1."".temc])1'stown, Pa" on this 1 th day of March, 20.0.0../' ../ " ,-,..., /' // . " / Ij12JTH7" ..- /" / ,. // SCHBEIN-COHEN .. f~ -, , ,- .' -"" ~ ". ~ ,'~~." .,~,~,,,",,.,,,,",,,,,,,,,,,,,,,,,;J;",,",~"-';;J:l_~"'I'''I!' =_ ,....,_"""''''!'......",~!1Il "-,,,~ 91~ ~> o S;; :S- '"U OJ t"T1rT'i Z:JJ :Z:C (J) k: , .' ~C:) ?z-; :z:C- 5) c :z: ~ ~ i. '.',;-,>,-'<:-'{" o o o " ::-.1 ih;t;~ -nf11 :-~5 '1' (~C) T"Ti ,-..)::D c_.o /-rn o --l :;> ~ - -- T..... ;;0 N N "" :]: CE N -.l LARRY J. BANNON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 1276 CIVIL TERM MARGARET ANN BANNON, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that Plaintiff's 30l(d) Affidavit was served upon the Defendant by depositing it in the United States mail, postal pre-paid, addressed to her attorney, Michael J. Pykosh, on April 25, 2002. ~Mtl>. ~ Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 1~~7"'~ .. "'_'''')Ii_,',~,'~' "_"'_(~(!?j,_ "'-;'- "'",,. --~--"-'''''.,j_~__~_''' ,_ "->> ~'_,~-'_I;t"...- _-,~_ ~'",_ - ." '''C-".'. -', .,.-, ,',~'- ,"-=-' -" , , ,,-, ,.- ,~ ~ ,,",,. . .'_c_. - ~" ~_w 0 0 '""" u C r'V -n Z' 1:?> IJr:; -'0 -. ~~~ :::0 .- ZC (;...) ~~;( 0 ~'~~) ~ )>c: --is. ~~C< :5 :PC Z U'1 :::J C) ~ '_":"f5-"~ ''',,,~7.-- __"'"""" " ~~. "~I!JIIlIIl!ilRI!IIW!~ ~ ,,~- "'- -- .~ ... .. .LL .,. LARRY J. BANNON, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000- 1276 CIVIL TERM MARGARET ANN BANNON, DEFENDANT IN 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 twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on April 20, 1999 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 of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: o~-;H!- O~ ~~ L J. Bannon ::~, "'''__' ___~" ,,~~,' ~,,_ c',c," ~, =. -,,~~,-. -. ~ , -.,- ~~,,~. . ..,.,=~ ,,- ~. ,- I_~=- 0 0 0 C f'V -n ~~::: j;;\Pr _._~ -0 rD "1':' rnp,_ :;,;:t ZX, ~) zc- ~5:~' Cl f'.'" C ~ ';P" -,...;: --,r z5.:~ c:..~ 4~1 Sl ~ C ?~ en -c C) ~. ~,~ ~ " -. III "'- ,.~ H105.157REV.5-97 COMMONWEALTH OF PENNSYlVANIA DEPARTMENT OF HEALTH VITAL RECORDS STATE ALE NUMBER DIVORCE [kJ RECORD OF OR ANNULMENT STATE FILE DATf; cou"", Cu.Ik-bcrIQIIJ (CHECK ONE) o 1. NAME 3. RESIDENCf:; 7tJ 2 5. NUMBER OF THIS MARRIAGE B. MAIDEN NAME 10. RESIDENCe: 1f1z:1.. S 12. NUMBER OF THIS MARRIAGa 15. PLACE OF THIS MARRIAGa 17A. NUMBEI; OF CHILDRE:N THIS MARRIAGE 0 20. NUMBER OF CHILDREN TO CUSTODY OF 22. DATE OF DECREE 24. SIGNATURE OF TRANSCRIBING CLERK HUSBAND f1 A (_111) ~ (Day) Il. (Ve"l Z. (First) '-tV r ~torR.O. (Last) Balllt.,,, (Middle) ;nh"" (State or Foreign Country) I-I IJ1 WIFE ILas~ 130 c c i State (V....) J IMonIhI IDay) 9 (State or Foreign Country) I-I liNN Strsstor R.D. I'd City, Bom. or Twp. County 1J1le.. C 1M III 11,( 3. RACE WHITE OTHER(Specify) fPfi I (County) C/flltlfl~ 7B. NUMBER OF DEPENDENT CHILDREN UNDER 18. f 16. DATE OF (Month) THIS 2 MARRIAGE 9. DECREE GRANTED TO HUSBAND g] WlFE o OTHER (Spedfy) o (Day) (V"') ( 8"0 18. PLAINTIFF HUSBAND ~ OTHER (SpecJfy) o WIFE o tV)/Je (Year) HUSBAND o WIFE o SPUT CUSTODY OTHER (Specify) o 0 (Month) (Day) (Year) 23. DATE REPORT SENT TO VITAL RECORDS """"'lW ,