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Home My WebLink About00-01515 LORI ANN SHATTO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000- 1515 G:wS2T01m CIVIL ACTION - LAW IN DIVORCE MICHAEL LYNN SHATTO, 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 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. IF YOU DO NOT F~E 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 FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A. 17013 (717) 249-3166 1-800-990-9108 1'.... .--. " -~ , - - VS. IN TIIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2000- /5JS ~ 'Iv.- LORI ANN SBATTO, Plaintiff MICHAEL LYNN SBATTO, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) QF THE DIVORCE CODE 1. The Plaintiff is Lori Ann Shatto, an adult individual who currently resides at 21 Nottingham Road, Camp Hill, Cumberland County, Pennsylvania 17011 and whose social security number is 174-54-3373. 2. The Defendant, Michael Lynn Shatto, is an adult individual, who is currently incarcerated in the 105 Bryon Nelson Circle, Etters, York County, Pennsylvania 17319 and whose social security number is 175-48-3664. 3. Plaintiff and Defendant were married on February 8, 1993 in Ellicott City, Maryland. -1- I"""'.I!: _or ~I:. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this fIling. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff and Defendant are both citizens of the United States. 7. There has been no prior action for divorce fIled in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has wflived said right. 9. There are no children born of the marriage. -2- " 1-' - ,~ - " ~ ~, ..> 10. Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, DILS & RUPICH BY: Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, P A 171 02 (717) 232-9724 lD. No. 07056 -3- , ,$i~ > , " . V.E R f Fie A T ION 1 \/erify that the statements made in this c.. .....0'1. ;, +- ,'" Pi.. '"<,, 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: 1hcfrcf. (II 2A r r bf(}u- ~ ~- t/I'f~ try () I~ .2J~ , , , , : LORI ANN SHATTO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 2000-1515 MICHAEL LYNN SHATTO, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFE~ AND CLAIM RIGlITS 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 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. 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 HA VB 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 1-800-990-9108 ".. ,- ~~,~ ". """1'7'"1- .1_ I - LORI ANN SHATTO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA Vs. NO. 2000-1515 MICHAEL LYNN SHATTO, IN DIVORCE Defendant AMENDED COMPLAINT IN DIVORCE AND NOW, this zhay of April, 2000, comes Lori Ann Shatto, by her attorney, Arthur K. Dils, Esquire and respectfully avers the following: 1. Paragraphs one (1) through ten (10) (a) of the Complaint in Divorce are incorporated herein and made hereof by reference. 11. Plaintiff further avers that the Defendant has offered such indignities to her person, the innocent and injured spouse, so as to render her condition intolerable and life burdensome. I, :"~ , . I ~-:"'f-~' I r- " '-' WHEREFORE, Plaintiff respectfully prays your Honorable Court to grant a Decree in Divorce on the grounds of indignities. CI,AIM FOR EQUITABLE DISTRIBUTION 12. Plaintiff avers that Plaintiff and Defendant are the joint owners of various pieces of real estate, which are subject to equitable distribution by your Honorable Court. 13. Plaintiff further avers that Plaintiff and Defendant are the joint owners of at least five motor vehicles, numerous household items, bank accounts, personal property and other items, which are subject to equitable distribution by your Honorable Court. 14. Plaintiff avers that Plaintiff and Defendant are the joint owners of a business, which is subject to equitable distribution by your Honorable Court. -2- "'".,-~, ~~ ,r ~ " : WHEREFORE, Plaintiff respectfully requests your Honorable Court to equitably distribute all marital property. CLAIM FOR AUMONY PENDENTE LITE, ALI.M..ONY, COUNSEL FEES, COSTS AND EXPENSES 15. Plaintiff avers that Defendant fired her from their jointly owned business upon the date of separation, leaving the Defendant with no source of income whatsoever. 16. Plaintiff avers that Defendant took the one vehicle which she was driving after the separation, unanounced, leaving her with no transportation. 17. Plaintiff avers that the various pieces of real estate, the business, and personal property will have to be evaluated for purposes of equitable distribution. 18. Plaintiff does not have sufficient funds to support herself during the pendency of this divorce action. -3- '~','_. w ,_, w, ,~,. ,". ,. : 19. Plaintiff does not have sufficient funds to expend for appraisals and evaluations during the pendency of this divorce action. 20. Plaintiff does not have sufficient funds to pay counsel fees, costs and expenses incidental to this divorce action. 21. Defendant does have sufficient funds to pay Plaintiff alimony pendente lite during the divorce action. 22. Defendant does have sufficient funds to pay all costs, expenses and Plaintiff's attorneys fees incidental to this divorce action. WHEREFORE, Plaintiff respectfully prays your Honorable Court to Order -4- ,~". > '" ,. ,- the Defendant to pay Plaintiff alimony pendente lite, and all costs, expenses and attorneys fees incidental to this divorce action. Res y submitted, -5- <f" '-,- ""~ , .., Arthur K. Di1s, squire 1017 North Front Street Harrisburg, Pa. 17102 (717) 232-9724 LD. No. 07056 VERIFICATION I verify that the statements made in thiS~t3fi/.tJ9 tJ/17/M/df are true and correct. [understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 rdating to unsworn falsitication to authorities. Date: LfI;;;L~IDO ~~. () ~ )/Y/ /-c9/;/1/ft; '''~ '^"" ., - -~ , I : . .. I, Arthur K. Dils, Esquire hereby certify that a true and correct copy of the within Amended Complaint in Divorce has been served upon the following individual by depositing a cop ofth(( same in the United States Mail, First Class Mail, on the M day of , 2000 to the following address: Michael Lynn Shatto 105 Bryon Nelson Circle Etters,PA. 17319 BY: Arthur K. Dils, Esquire 10 17 North Front Street Harrisburg, P A 17102 (717) 232-9724 ID. No. 07056 Date: April 25, 2000 !I ,.,-~, -, '"', 1"""- - ... LORI ANN SHATTO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2000-l5l5 Civil Term MICHAEL LYNN SHATTO, Defendant CIVIL ACTION - LAW IN DIVORCE PRELIMINARY OBJECTIONS AND NOW, TO WIT, this ~ day of April, 2000, comes the Defendant, Michael L. Shatto, by and through his attorneys, Anstine & Sparler, and files Preliminary Objections to the Divorce Complaint filed by the Plaintiff. 1. Plaintiff, Lori Ann Shatto, hereinafter referred to as "Wife", resides at 21 Nottingham Road, Camp Hill, Cumberland County, Pennsylvania 17011, and has lived there since December 23., 1999. Wife has continued to maintain her residence in York County. 2. Defendant, Michael L. Shatto, hereinafter referred to as "Husband", resides at 105 Bryon Nelson Circle, Etters, York County, Pennsylvania 17319. 3. Wife filed a Complaint in Divorce to the above term and number on March 15, 2000. 4. pennsyl vania Rules of Civil Procedure 1920.6 provides, "If, within ninety days of service of the complaint, a second action is brought in another county and one of the two counties is the county in which the last family domicile was located and in which one of the parties continues to reside, the court of the county of the last family domicile shall determine, based upon the purposes of the Divorce Code, which of the two actions shall be stayed and which shall proceed..." Anstine & , Sparler ,i ArrORNEYSArlAw Anstine & Spar/er AnOIllVfYSArLAw "" .. , 5. Husband filed a Complaint for Divorce in York. County on April 27, 2000. 6. The last marital domicile is located in York County and Husband continues to reside in York County. 7. There are no compelling reasons that venue would be proper in Cumberland County. WHEREFORE, Defendant prays your Honorable Court to dismiss Plaintiff's Divorce Complaint. Respectfully submitted, ANSTINE & S arler, Esquire Defendant arket Street nsylvania 17401 -8811 1. D. #07435 :i '; i; !i Ii I 'I " Ii i i I ! I I Ii I, i I Anstine & II Spar/er :i AlTo~NtYSAfLAW " , I' , , 1-: !! !_,'i.<lI I CERTIFICATE OF SERVICE AND NOW, thiS!JJP: day of ~~ 2000, 1. KENNETH J. SPARLER, ESQUIRE, of the law firm of Anstine .& Sparler, hereby certify that I have, this date, served a copy of the attached Preliminary Objections by first class, United States Mail, addressed to the party or attorney of record as follows: Arthur K. Dils, Esquire DILS & RUPICH 1017 North Front Street Harrisburg, PA l7l02 ANSTINE & SPARLER -~.-:> By: ==,,-~--. '" ,Kenneth J. parl r, Esquire Counsel for fe dant 117 East Market Street York, PA l7401 (717) 846-8811 Sup. Ct. I.D. #07435 Anstine & Sparler ArrOIlM"YSArLAw I"~" ~ VERIFICATION The undersigned verifies that the statements made in the foregoing Preliminary Objections, which are within the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believe them to be true. And furt"her, this Verification is signed on the recommendation of my attorneys, who advise me that the allegations and language in this document are required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understood that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave the determination of these matters to my attorneys on their advice. I understand that all statements herein are made subject to the penalties of ~4904 relating to unsworn 18 Pa.C.S.A. falsifications to authorities. ~~ Michae L. Shatto / LORI ANN SHATTO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2000-1515 Civil Term MICHAEL LYNN SHATTO, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR LISTING CASE FOR ARGUMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY; 1. State matter to be argued; Preliminary Objections 2. Identify counsel who will argue case; (a) for plaintiff; Arthur K. Dils, Esquire DILS & RUPICH 1017 North Front Street Harrisburg, PA 17102 (b) for defendant; Kenneth J. Sparler, Esquire ANSTINE & SPARLER 117 East Market Street York, Pennsylvania 1740l 3. I will notify all parties in writing within two (2) days that this case has been listed for argument. 4. Argument Court Date; July 26, 2000 / Dated; ?;{~ ?'-< c::::; . S arler, Esquire r Defendant rket Street York, PA l740l (717) 846-8811 Sup. Ct. I.D. #07435 Anstine & Sparler ArroRNEvsArLAw 'i;'~" . - ,~ CERTIFICATE OF SERVICE AND NOW, this . <I-h ( %'. /J ~ day of -/ r lt2u~ ESQUIRE, of the law fiim of 2000, I, KENNETH J. SPARLER, Anstine & Sparler, hereby certify that I have, this date, served a copy of the attached Praecipe for Listing Case for Argument by first class, United States Mail, addressed to the party or attorney of record as follows: Arthur K. Dils, Esquire DILS & RUPICH 1017 North Front Street Harrisburg, PA 17102 ANSTINE & SPARLER By ,0 Sparler, Esquire r Defendant rket Street 7401 (717) 846- 811 Sup. Ct. I.D. #07435 Anstine & Sparler ArrOI'lNEYSArLAw ,,,-:>!! .,... :p~~II'!@lII!~lII!lt~_ __.~~~~(~ .1'1i'!11. -.- -, (") 0 () C 0 >'11 s:: 5= .._~ "'00:1 ~ :~fg rn [1'1 Z Z~n I ..,-,fT"l zc .-~~i-? Cf) ";.-~ N -<2" ~~C) \<CJ --0 ;~~:B ~O :1;:: '1"'0 >0 ~ c5rr'l c: ~ '" ;i;! ~ ~ ","~"",,,,"'~!!ii'~~'liw'~""'''m~fG!~IIffl''I'Rii<~I!''I'-",,!~-I;mrn<!!!\~''''l'JlI'lrlr~n:m"!Il;<1~J:iJ.l'~.lIjNI~t Anstine & Sparler ArrOIlNHsAILAW LORI ANN SHATTO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1515 MICHAEL LYNN SHATTO, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TERMINATE DIVORCE ACTION TO THE PROTHONOTARY: Please terminate and discontinue the above-captioned divorce action. Respectfully submitted, :~ Arthur K. Dils, Esquire Counsel for Plaintiff 1017 North Front Street Harrisburg, PA l7102 (717) 232-9724 Sup. Ct. I.D. No. 07056 ............ . , ^ ~. o If~ ~"cc' rnrl': ~~~. '2'~ ~? i~._~) ';J;>'C:' ..-;/ :::i. ..< c:> "-'J ~~ C) -~:'J -- C) "d ,,) '" ,," :Xl :::::> fv '~'... 1f\Ill"''''''~1 ,.", I, 1J~!'!__~__~~!~___Mlf'll'l'!l"IIl;Imft!m!~f~~~\f""'-~~'-q';wffli'mlf-i1~"-<fl!l~~'l1'!l!~lIil!i';i*'1~.\l>!>"",,"'lmI!\>""'","l,,<f_~l~~~~ LORlANN SHATTO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2000-1515 Civil Term MICHAEL LYNN SHATTO, Defendant IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW, this 14y of July, 2000, comes Arthur K. Dils, Esquire, the attorney for the Plaintiff, Lori Ann Shatto, and respectfully requests the following: 1. Your Petitioner is Arthur K Dils, Esquire, the Attorney for Lori Ann Shatto, whose office is located at 1017 North Front Street, Harrisburg, Pennsylvania 17102. 2. The Respondent is the Defendant, Michael Lynn Shatto, who is represented by Attorney Kenneth J. Sparler whose office is located at 117 E. Market Street, Yark, Pennsylvania 17401. -ill~, r ' !- '! ' 3. An Amended Complaint in Divorce was filed on behalf of the Plaintiff, Lori Ann Shatto, the Plaintiff, on April 27, 2000, which included claims for alimony, alimony pendente lite, equitable distribution, counsel fees, costs and expenses. 4. Said Amended Complaint in Divorce is incorporated herein and made apart hereof by reference. 5. It is respectfully requested that Plaintiff be awarded alimony pendente lite. WHEREFORE, Plaintiff, Lori Ann Shatto, by her attorney, Arthur K. Dils, Esquire, your Petitioner, respectfully requests that Lori Ann Shatto be awarded alimony pendente lite. BY: rthur K. Dils, Esquire 1017 North Front Street Harrisburg, Pa. 17102 (717) 232-9724 LD. No. 07056 -2- , .. 1-- "I 1"- 1 ' VERIFICA TION The undersigned, Arthur K. Dils, Esquire, hereby verifies and states that: 1. He is the attorney for Lori Ann Shatto. 2. He is authorized to make this verification on her behalf. 3. This verification is made by counsel pursuant to Pa. R.C.P., Rule I 024( c). 4. The statements set forth in the foregoing Petition are true and correct to the best of his knowledge, information and belief. 5. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904, relating Arthur K. Dils, Esquire Date: July 7, 2000 "~" - ,~- T , .~ " . 1- . . CERTIFICATE OF SERVICE I, Arthur K. Dils, Esquire hereby certify that a true and correct copy of the within Praecipe has been served upon the following individual by depositing a copy of the same in the United States Mail, First Class Mail, on the? day of July, 2000 to the following address: Kenneth J. Spader, Esquire 117 East Market Street York, Pa. 17401 BY Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, P A 171 02 (717) 232-9724 LD. No. 07056 Date: July 7,2000 , I -,