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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
WENDY L. VANSCYOC,
PENNA.
Plaintiff
No.
00-2203 CIVIL TERM
VERSUS
MICHAEL S. VANSCYOC,
Defendant
AND NOW,
DECREED THAT
AND
DECREE IN
DIVORCE
MfJ 7
~ 3.'!fJ/.M.
2003
, IT IS ORDERED AND
WENDY L. VANSCYOC
, PLAINTIFF,
MICHAEL S. VANSCYOC
, 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;
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WENDY L. VANSCYOC,
IN TIlE COURT OF CCMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 00-2203 CIVIL TERM
vs.
MICHAEL S. VANSCYOC,
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information; to the court
for ,::ntry of a divorce decree:
1. Grounds for divorce: irretrievable breakdown under Section 3301 (c)
~~ of the Divorce Code. (Strike out inapplicable section)
2. Date and manner of service of the complaint: Mailed to Defendant via
certified mail, restricted delivery on April 14, 2000 and received by Defendant on
April 17, 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 the plaintiff
April 28, 2003
by the defendant
April 25, 2003
B. (1) Date of execution of the plaintiff's affidavit required by
Section 3301 (d) of the Divorce Code:
(2) Date of service of the plaintiff I s affidavit upon the defendant:
4. Related claims pending:
None~
5. Indicate date and manner of service of the notice of intention to file
praElcipe to transmit record. and attach a copy of said notice under Section
3301 (d)(l)(i) of the Divorce Code Waiver of Notice signed by Plaintiff on April 28, 2003
and filed con=rently herewith; Waiver of Notice signed by Defendant on April 25, 2003
and filed con=rently,herewith.
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Attorney for' Plaintiff~
Melissa Peel Greevy
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WENDY L. VANSCYOC
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
MICHAEL S. VANSCYOC,
Defendant.
CIVIL ACTION - LAW
,u,03
No.dOX'l- Civil 2000
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
foregoing 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 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 other 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:
Office of the Prothonotary
Cumberland County Court House
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, Pennsylvania 17013
Telephone: (717) 249-3166
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WENDY L. VANSCYOC
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
MICHAEL S. VANSCYOC,
Defendant.
No. tJ1J- .l.Ja.JCivil 2000
IN DIVORCE
NOTICE OF A V AILABIUTY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302( d) of the Divorce Code, you may request that the court require you
and your spouse to attend marriage counseling prior to a divorce being handed down by the court.
A list of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver
of your right to request counseling.
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WENDY L. VANSCYOC,
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
MICHAEL S. VANSCYOC,
Defendant.
No.01l..1J.03 Civil 2000
IN DIVORCE
COMPLAINT IN DIVORCE UNDER ~ 3301 (c) or ~ 3301(d) OF THE DIVORCE CODE
Plaintiff, by and through his attorney, Melissa Peel Greevy, respectfully represents:
1. Plaintiff is Wendy 1. VanScyoc, who currently resides at 407 Penn Ayr Road,
Camp Hill, Cumberland County, Pennsylvania, since February 27, 2000.
2. Defendant is Michael S. VanScyoc, who currently resides at 5313 Ridge Road,
Elizabethtown, Dauphin County, Pennsylvania, since January 1999.
3. Plaintiffs Social Security Number is 183-64-6385.
4. Defendant's Social Security Number is 188-68-1190.
5. Plaintiff and Defendant have both been bona fide residents of the Commonwealth
of Pennsylvania for a period of more than six months immediately preceding the filing of this
Complaint.
6. The parties were married on September 28,1996 in Mechanicsburg, Cumberland
County, Pennsylvania.
7. There are no minor children of the marriage.
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8. Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
9. There have been no prior actions of divorce or annulment between the parties.
10. The marriage is irretrievably broken.
11. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request the court require the parties to participate in counseling.
12. Plaintiff requests the court to enter a decree of divorce.
13. The parties may, but have not yet, entered a written agreement with regard to
propelty division.
WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce,
divorcing Plaintiff and Defendant.
COUNT II
EOUlTABLE DISTRIBUTION
14. Paragraphs I through 13 of this Complaint are incorporated by reference as
though set forth at length.
15. Plaintiff and Defendant have acquired property during the course of their marriage
until the date of their separation.
16. Plaintiff and Defendant have not entered an agreement as to an equitable division
of said property.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital
property.
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I verifY that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to
Date: 4~ l \ . a:::)
unsworn falsification to authorities.
Date: 4- / /.2-0 uV
Respectfully submitted,
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Melissa Peel Greevy, EsqUire
J.D. No. 77950
214 Senate Avenue Suite 602
Camp Hill, PA 17011-2336
(717) 763-8995
Counsel for the Plaintiff
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WENDY L. VANSCYOC,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
MICHAEL S. VANSCYOC,
Defendant
NO. 2203 Civil 2000
IN DIVORCE
RETURN OF SERVICE
(United States Mail)
The undersigned makes the following return of service:
LAINT was mailed to MICHAEL S. VANSCYOC on April 14, 2000 at
.m. at 214 SENATE AVENUE, CAMP HILL, PA 17011:
The signed receipt, indicating service was made on 4/17/2000, is attached.
The mail, refused and returned, is attached. A copy mailed to the defendant
at the same address by ordinary mail with the return address of the sender
appearing thereon has not been returned within fifteen days after mailing.
SIGNATURE AND AFFIDAVIT
I, Melissa Peel Greevy, Esq., certitY that I am a competent adult not a party to the action.
I veritY that the statements made in this affidavit and return of service are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. paragraph
4904 relating to unsworn falsification to authorities.
Date: 4/20/00
U/p:tq~
Melissa Peel Greevy, Esquire
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WENDY L. VANSCYOC,
Plaintiff
v.
MICHAEL S. VANSCYOC,
Defendant
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IN THE COURT OF COMMON PLEAS
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CIVIL ACTION - LAW
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1; _ Complete- items 3, 4a, and 4b~ -
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.. card_to ~u.
= -Attach this form to the front of the maflplece, or on the back if space does not
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CD - -Write-Return Receipt Requested- on the mailpiece below th~ artlC:le number.
-5 -The RetLlm Receipt will show to whom the article was delivered and the date
c delivered.
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NO. 2203 Civil 2000
IN DIVORCE
I 8JSQ wish to receive the
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1. 0 Addressee's Address
2. ~rlcted Delivery
Consult postmaster for fee.
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Johnson, Duffie, Stewart & Weidner
By: Melissa Peel Greevy
J.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2203 CIVIL TERM
WENDY L. VANSCYOC,
v.
MICHAEL S. VANSCYOC,
CIVIL ACTION - LAW
IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1.
11,2000.
A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on or about April
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of filing and service the Complaint.
3, I consent to the entry of a final decree in divorce after service of notice of intention to request
entry of the decree.
4. I have been advised of the availability of marriage counseling, understand that the Court
maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate
in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in
counseling prior to the divorce becoming final.
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. 94904 relating to unsworn falsification to
aullhorities.
Date: 11- ws - 03
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Johnson, Duffie, Stewart & Weidner
By: Melissa Peel Greevy
J.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyoe, Pennsylvania 17043-0109
(717)761-4540
Attorneys for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2203 CIVIL TERM
CIVIL ACTION - LAW
WENDY L. VANSCYOC,
v.
MICHAEL S. VANSCYOC,
IN DIVORCE
Defendant
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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. 94904 relating to unsworn falsification to
aullhorities.
Date: '1- Olf?- 03
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Johnson, Dnffie, Stewart & Weidner
By: Melissa Peel Greevy
J.D. No. 77950
301 Market Street
P. O. Box 109
L(:moyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2203 CIVIL TERM
WENDY L. VANSCYOC,
.ill
v.
CIVIL ACTION - LAW
MlICHAEL S. VANSCYOC,
IN DIVORCE
Defendant
AFFIDA VIT OF CONSENT
1.
11,2000.
A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on or about April
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of filing and service the Complaint.
3. I consent to the entry of a final decree in divorce after service of notice of intention to request
entry of the decree.
4. I have been advised of the availability of marriage counseling, understand that the Court
maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate
in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in
counseling prior to the divorce becoming final.
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. 94904 relating to unsworn falsification to
authorities.
Date:
:211888v3
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J~)hnson, Duffie, Stewart & Weidner
By: Melissa Peel Greevy
J.D. No. 77950
30 I Market Street
P. O. Box 109
L(:moyoe, Pennsylvania 17043-0109
(717)761-4540
Attorneys for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2203 CIVIL TERM
WENDY L. VANSCYOC,
v.
I- MICHAEL S. VANSCYOC,
CIVIL ACTION - LAW
IN DIVORCE
Defendant
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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. 94904 relating to unsworn falsification to
authorities.
Date:
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WENDY L. VANSCYOC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2000-2203 CIVIL TERM
MICHAEL S. VANSCYOC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
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DEFENDANT'S ANSWER TO PETITION FOR SPECIAL RELIEF
AND NOW, comes the Defendant, MICHAEL S. VANSCYOC, by his attorney, MAX J.
SMITH, JR., Esquire, and respectfully responds as follows to the Petition for Special Relief:
1. -5. Admitted.
6. Admitted. By way of further response, the parties were financially overextended
at the time the house was acquired.
7. Admitted. By way of further response, Wife left the house voluntarily, and not at
Husband's request. It would not make sense for Wife to leave and Husband to also vacate the
house as the household expenses needed to be paid.
8. Admitted. By way of further response, Husband's efforts to refinance the house
were unsuccessful, as he could not qualify, given his income and expenses.
9. Admitted. By way of further response, Husband has executed a contract for the
sale'purchase of the residence, and expects that Wife will execute same in the next several days.
10. Admitted. By way of further response, due to Wife's unexpected departure from
the marital residence, Husband did not have sufficient income with which to pay the mortgage
and other household expenses.
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11. Denied. Husband is without knowledge as to the truth of this averment, and strict
proof thereof is demanded at hearing.
12. Admitted.
13. Admitted. By way of furtherresponse, Husband's financial situation made it
impossible for him to pay the mortgage payments for said months.
14. Admitted. By way of further response, the income as stated for Wife exceeds that
of Husband at the time of the parties' separation.
15. Denied. Had Wife remained in the marital residence, the parties' .joint income
would have been sufficient to pay the mortgage and household expenses. Her departure from the
residence is the primary reason that mortgage foreclosure became imminent.
16. Admitted. By way of further response, Wife is not entitled to support or alimony
pendente lite as a matter of law.
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17. Denied. The averment as stated is a legal conclusion to which no reply is
necessary.
18. Denied. Husband did not have sufficient income or means to pay the mortgage, in
light of Wife's voluntary departure from the marital residence. Thus, Wife's conduct is as
responsible as any factor in the real estate being on the brink of foreclosure.
19. Denied. The parties are jointly responsible for paying the mortgage and other
household expenses, and therefore any expenses which may be due and owing at the time of
closing are the responsibility of both parties, not Husband alone.
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20. By way of further response, it appears as though the house has in fact been sold,
as the contract for sale is awaiting Wife's signature.
21. Denied. Husband assisted in marketing the house for sale to the best of his
ability, did everything which was requested of him by the realtor, and kept in regular contact
with the real estate agent.
22. Denied. Husband is without knowledge as to the truth of this averment, and strict
proof thereof is demanded at hearing.
23. Denied. Husband is without knowledge as to the truth of this averment, and strict
proof thereof is demanded at hearing.
24. Admitted. By way of further response, Husband could not meet the requirements
of the mortgage lender to assume the balances of the two mortgages.
25. Admitted. By way of further response, Husband also received said notices of
foreclosure by mail.
26. Admitted. By way of further response, since is appears as though the house has
now been sold, the Deed in Lieu of Foreclosure issue has been rendered moot.
27. Denied. Defendant's counsel herein has met with Husband for the purpose of
responding to this Petition.
28. Admitted.
29. Denied. Any attorney fees and costs incurred by Wife are the result of her
actions.
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30. Denied. Husband is without knowledge as to the truth of this averment, and strict
proof thereof is demanded at hearing.
WHEREFORE, Defendant respectfully requests that the Petition for Special Relief filed
by Plaintiff be dismissed with prejudice at Plaintiff s expense.
Respectfully submitted,
Date: June 5,2001
MAX J. SMITH, JR., E e
LD. No. 32114
James, Smith, Durkin & Connelly LLP
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
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I verify that the statements made in this Answer 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.
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WENDY L. VANSCYOC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2000-2203 CIVIL TERM
MICHAEL S. VANSCYOC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
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CERTIFICATE OF SERVICE
AND NOW, this ~ day of June, 2001, I, MAX J. SMITH, JR., Esquire, Attorney
for Defendant, hereby certify that I have this day sent a copy of Defendant's Answer to Petition
for Special Relief by depositing a certified copy ofthe same in the United States mail, postage
prepaid, at Hershey, Pennsylvania, addressed to:
Melissa Peel Oreevy, Esquire
214 Senate Avenue, Suite 105
Camp Hill, PA 17011
MAX J. SMITH, JR., Esq e
J.D. No. 32114
James, Smith, Durkin & Connelly LLP
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
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\VENDY 1. VANSCYOC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2000-2203 CIVIL TERM
l'vITCHAEL S. VANSCYOC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
DEFENDANT'S ANSWER TOPETffiON FOR SPECIAL RELIEF
AND NOW, comes the Defendant, MICHAEL S. VANSCYOC, by his attorney, MAX J.
SMITII, JR., Esquire, and respectfully responds as follows to the Petition for Special Relief:
1.-5. Admitted.
6. Admitted. By way of further response, the parties were financially overextended
at the time the house was acquired.
7. Admitted. By way of furtherresponse, Wife left the house voluntarily, and not at
Husband's request. It would not make sense for Wife to leave and Husband to also vacate the
house as the household expenses needed to be paid.
8. Admitted. By way of further response, Husband's efforts to refinance the house
were unsuccessful, as he could not qualify, given his income and expenses.
9. Admitted. By way of further response, Husband has executed a contract for the
sale-purchase of the residence, and expects that Wife will execute same in the next several days.
10. Admitted. By way of further response, due to Wife's unexpected departure from
the marital residence, Husband did not have sufficient income with which to pay the mortgage
lmd other household expenses.
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,11. Denied. Husband is without knowledge as to the truth of this averment, and strict
proof thereof is demanded at hearing.
12. Admitted.
13. Admitted. By way of furtherresponse, Husband's financial situation made it
impossible for him to pay the mortgage payments for said months.
14. Admitted. By way of further response, the income as stated for Wife exceeds that
of Husband at the time of the parties' separation.
15. Denied. Had Wife remained in the marital residence, the parties'.joint income
would have been sufficient to pay the mortgage and household expenses. Her departure from the
residence is the primary reason that mortgage foreclosure became imminent.
16. Admitted. By way of further response, Wife is not entitled to support or alimony
pendente lite as a matter of law.
17. Denied. The averment as stated is a legal conclusion to which no reply is
necessary.
18. Denied. Husband did not have sufficient income or means to pay the mortgage, in
light of Wife's voluntary departure from the marital residence. Thus, Wife's conduct is as
:responsible as any factor in the real estate being on the brink of foreclosure.
19. Denied. The parties are jointly responsible for paying the mortgage and other
household expenses, and therefore any expenses which may be due and owing at the time of
closing are the responsibility of both parties, not Husband alone.
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- 20. By way of further response, it appears as though the house has in fact been sold,
as the contract for sale is awaiting Wife's signature.
21. Denied. Husband assisted in marketing the house for sale to the best of his
ability, did everything which was requested of him by the realtor, and kept in regular contact
with the real estate agent.
22. Denied. Husband is without knowledge as to the truth of this averment, and strict
proof thereof is demanded at hearing.
23. Denied. Husband is without knowledge as to the truth of this averment, and strict
proof thereof is demanded at hearing.
24. Admitted. By way of further response, Husband could not meet the requirements
of the mortgage lender to assume the balances of the two mortgages.
25. Admitted. By way of further response, Husband also received said notices of
foreclosure by maiL
26. Admitted. By way of further response, since is appears as though the house has
now been sold, the Deed in Lieu of Foreclosure issue has been rendered moot.
27. Denied. Defendant's counsel herein has met with Husband for the purpose of
responding to this Petition.
28. Admitted.
29. Denied. Any attorney fees and costs incurred by Wife are the result of her
a.ctions.
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- 30. Denied. Husband is without knowledge as to the truth of this averment, and strict
proof thereof is demanded at hearing.
WHEREFORE, Defendant respectfully requests that the Petition for Special Relief filed
by Plaintiff be dismissed with prejudice at Plaintiff s expense.
Respectfully submitted,
Date: June 5, 2001
~~
J.D. No. 32114
James, Smith, Durkin & Connelly LLP
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
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I verify that the statements made in this Answer 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.
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Micnael s. van$Gyoc
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'vVENDY 1. VANSCYOC,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2000-2203 CIVIL TERM
IV1ICHAEL S. VANSCYOC,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this ~ day of June, 2001, I, MAX J. SMITH, JR., Esquire, Attorney
for Defendant, hereby certify that I have this day sent a copy of Defendant's Answer to Petition
for Special Relief by depositing a certified copy of the same in the United States mail, postage
prepaid, at Hershey, Pennsylvania, addressed to:
Melissa Peel Greevy, Esquire
214 Senate Avenue, Suite 105
Camp Hill, PA 17011
~~
MAX J. SMITH, JR., Esq . e
J.D. No. 32114
James, Smith, Durkin & Connelly LLP
P.O. Box 650
Hershey, P A 17033
(717) 533-3280
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WENDY L. VANSCYOC
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
MICHAEL S. VANSCYOC,
Defendant.
No. 00-2203 Civil Term
IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certifY that on this 31 st day of May 200 I , a true and correct copy of the
foregoing Petition for Special Relief and Rule to Show Cause dated May 30, 2001 was served
upon the following by depositing the same into the United States Mail, first-class mail, postage
pre-paid to:
Max J. Smith, Jr, Esquire
P.O. Box 650
Hershey, PA 17033
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WENDY L. VANSCYOC
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
MICHAEL S. VANSCYOC,
Defendant.
No. 00-2203 Civil Term
IN DIVORCE
AND NOW, this
RULE TO SHOW CAUSE
JO~ day of fIIl~, 2001, upon consideration of the
Plaintiff/Petitioner's Petition for Special Relief, a Rule to Show Cause is hereby issued upon the
Defendant/Respondent to show cause why the Petition should not be granted.
RULE RETURNABLE
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DAYS FROM SERVICE.
J.
Distribution: Max J. Smith, Jr., Esq. P.O. Box 650 Hershey, PA 17033
Melissa Peel Greevy, Esq. 214 Senate Avenue Suite 105 Camp Hill, PA 17011
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WENDY L. VANSCYOC
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
MICHAEL S. VANSCYOC,
Defendant.
No. 00-2203 Civil Term
IN DIVORCE
ORDER OF COURT
AND NOW, this
day of
, 200 I, Plaintiff/Petitioner's
Petition for Special Relief is granted. It is hereby Ordered that:
A) The Respondent shall vacate the home at 5313 Ridge Road, Elizabethtown,
Dauphin County, Pennsylvania, immediately,
B) Respondent shall execute a deed return the home to the mortgage company in lieu
offoreclosure action, if the mortgage company will still agree to this resolution,
B) Petitioner is awarded attorney's fees and costs in the amount of $750.00,
C) Any additional expenses and interest, caused by Respondent's failure to pay the
mortgages in a timely fashion, be borne solely by Respondent,
D) All of Petitioner's post separation contributions to the marital home be paid to
Petitioner at the time of settlement should the home be sold, if proceeds are available therefore.
In the event there are not proceeds or there are insufficient proceeds at the time of sale, Petitioner
be due reimbursement in the amount of$3628.59 at the time of the resolution of the economic
aspects ofthe divorce matter.
BY THE COURT,
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CERTIFICATE OF SERVICE
I hereby certify that on this ~day of ~/ 200 L, a true and correct copy
of the foregoing Petition for Special Relief was serv~ following by depositing the
same into the United States Mail, first-class mail, postage pre-paid to:
Max 1. Smith, Jr, Esquire
P.O. Box 650
HerSheY'PA~
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WENDY L. VANSCYOC
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
CIVIL ACTION - LAW
MICHAEL S. VANSCYOC,
Defendant.
No. 00-2203 Civil Term
IN DIVORCE
PETITION FOR SPECIAL RELIEF
AND NOW, comes the Plaintiff, by and through her counsel, Melissa Peel Greevy,
Esquire and files the above referenced Petition and represents that:
I. Your Petitioner is Wendy 1. VanScyoc, (hereinafter referred to as "Wife") and is
the Plaintiff in the above captioned divorce action.
2. Your Respondent is Michael S. VanScyoc (hereinafter referred to as "Husband"),
and is the Defendant in the above referenced divorce action.
3. The parties were married on September 28, 1996.
4. The parties were separated on February 27,2000 with Husband residing in the
marital home.
5. Wife filed for Divorce on April II , 2000.
6. During the course of the marriage, the parties acquired the marital home which is
subject to a first mortgage with a payment in the amount of $929.93 per month and a second
mortgage with a payment in the amount of$154.26 per month.
7.
At the time of separation, Husband indicated he intended to retain the marital
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home.
8. In correspondence dated May 26,2000, Wife's counsel requested that Respondent
refinance the home in his name alone within sixty (60) days.
9. On or about July 5, 2000 Husband decided to list the home for sale in a contract
which terms expires in January 2001.
10. On or about August 28, 2000 Wife discovered that Husband had not paid the
mortgage the prior month.
il. In several attempts to prevent foreclosure, Wife paid two second mortgage
payments in September 2000, the first mortgage due for October I, 2000 and the second
mortgage payments due for October 2000, November 2000, and December 2000. Wife's post
separation contributions to the mortgages totaled $3071.62.
12. Husband retained counsel who filed Entry of Appearance dated October 26,2000.
13. Husband did not pay the first mortgage due for November 2000 and December
2000.
14. Wife is employed at Rite Aid Corporation making a weekly net income of
approximately three hundred fifty five ($355) dollars.
15. Wife, who does not reside in the home, is making a greater effort to protect the
parties credit and prevent foreclosure than is Husband who resides in the home, essentially rent
free.
16. Husband is paying no voluntary support to Wife and no Order for alimony
pendente lite is in place.
17. The Pennsylvania Support Guidelines presume that the spouse occupying the
marital residence will be solely responsible for payment of the mortgages, taxes and insurance on
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the property.
IS. Husband's refusal to pay the mortgage on the marital home amounts to dissipation
of marital real estate and may subject the parties to additional debt.
19. Because of Husband' s non payment of the mortgages, there are additional costs,
interest and expenses which the parties will be forced to bear at the time of closing, if the home is
sold.
20. The parties had the home listed for sale under a contract that expired April I,
2001.
21. On a number of occasions Wife received calls from the real estate agent that
Husband was not returning his calls or otherwise cooperating with the real estate agent.
22. Wife made additional investments to the marital home in effort to improve it's
marketability by the purchase of a water disinfecting system and paint. Wife has also invested
substantial amounts oftime painting in the home and cleaning the roof.
23. Wife has arranged a forbearance period with reduced payments for the months of
December 2000, January 2001 and February 2001 on the mortgage to prevent foreclosure.
24. In correspondence dated February 21, 2001, Husband's counsel reported that
Husband was exploring the possibility of assuming the mortgages.
25. On May 7, 2001 and May 9, 2001 Wife received Notices ofForec1osure in the
mail.
26. In cOlTespondence date May II, 2001 Wife's counsel inquire whether Husband
would agree to execute a deed in favor of the mortgage company, in lieu of foreclosure on the
home. Wife's counsel asked for a response by May IS, 2001.
27. Husband's counsel had received no response from his client as of May 16, 2001,
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but did promise to contact Wife's counsel if he heard from or was able to reach his client.
28. Upon reasonable belief, Husband continues to reside in the marital home.
29. Wife has incurred attorney's fees and costs as a result of Husband's non payment
of the mortgages.
30. Wife has suffered damage to her credit rating due to the impending foreclosure for
nonpayment of the mortgages on the marital home.
WHEREFORE, Petitioner prays this Honorable Court grant the Petitioner the following
relief:
a) Order the Respondent to vacate the home immediately and execute a deed return
the home to the mortgage company in lieu offoreclosure action, if the mortgage company will
still agree to this resolution,
b ) Award Petitioner reasonable attorney's fees and costs,
c) Order that the additional expenses and interest, caused by Respondent's failure to
pay the mortgages in a timely fashion, be borne solely by Respondent,
d) Order that all of Petitioner's post separation contributions to the marital home be
paid to Petitioner at the time of settlement should the home be sold, if proceeds are available
therefore,
e) Any other reliefto Petitioner deemed appropriate by this Honorable Court.
Date: ~/
Melissa Peel Greevy, Esquire
1. D. No. 77950
214 Senate Avenue Suite 105
Camp Hill, PA 17011-2336
(717) 763-8995
Counsel for Petitioner
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VERIFICATION
I verify that the statements made in this Petition for Special Relief are true and correct. I
understand that false statements herein are made subject to the penalties of IS Pa. S. ~ 4904,
relating to unsworn falsification to authorities.
Date:
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.NationaICilye
~Aortgage
National City Mortgage Co.
3232 Newmark Drive' Miamisburg, Ohio 45342
Telephone (937) 910-1200
Mailing Address:
P.O. Box 1820
Dayton, Ohio 45401-1820
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May 07, 2001
VANSCYOC WENDY L
407 PENN AYR RD
CAMP HILL, PA 17011
Loan No, 958258-4
Current Servicer: National City Mortgage
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) .
NATURE OF THE DEFAULT-- The MORTGAGE debt held by the above lender on
your property located at:
5313 Ridge Rd
Elizabethtown PA 17022
IS SERIOUSLY IN DEFAULT because:
YOU HAVE-NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month (s)
01/01/2001 - 05/01/2001
and the following amount(s) are now past due:
Monthly Payments
Late Charges
Less Suspense Balance
Total Due
4,828.65
256.76
.00-
5,085.41
YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION
(Do not use if not applicable):
HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days
HOW TO CURE THE DEFAULT
of the date of this notice BY PAYING THE TOTAL.AMOUNT PAST DUE TO THE
LENDER, WHICH IS $ 5,085.41, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD.
Payment@ must be made either by cash, cashier's check, certified check
or money order made payable and sent to:
National City Mortgage
Attn: Collection Cashier
3232 Newmark Dr.
Miamisburg, OH 45342
You can cure any other default by taking the following action within
THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable)
DR674 FT8
Page 1
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WENDY 1. VANSCYOC,
Plaintiff
vs.
MICHAEL S. VANSCYOC,
Defendant
: IN TIIE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2203 Civi12000
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO ENTER APPEARANCE
TO TIIE PROTHONOTARY:
Please enter the appearance of Max J. Smith, Jr., Esquire, as counsel for Michael S.
Vanscyoc, Defendant in the above-captioned matter.
C/)iPyrpJ
Max J. Smith, Jr., Esquire
1.D. No. 32114
James, Smith, Durkin & Connelly LLP
P.O. Box 6S0
Hershey, P A 17033
(717) S33-3280
Date: October 26,2000
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WENDY 1. VANSCYOC
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHAEL S. VANSCYOC
: NO. 2000-2203 CIVIL TERM
ORDER OF COURT
AND NOW, this I 9TH day of JUNE, 2001, after considering Respondent's
Answer to the Petition for Special Relief and it appearing that there are facts in dispute,
we will schedule a hearing at the request of either party.
Edward E. Guido, J.
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Melissa P. Greevy, Esquire
214 Senate Avenue
Camp Hill, Pa. 17011
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Max 1. Smith, Jr., Esquire
P. O. Box 650
Hershey, Pa. 17033
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Johnson, Duffie, Stewart & Weidner
By: Melissa Peel Greevy
LD. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2203 CIVIL TERM
WENDY L. VANSCYOC.
v.
CIVIL ACTION - LAW
MICHAEL S. VANSCYOC.
IN DIVORCE
Defendant
CERTlFICA TE PREREQUISITE TO SERVICE OF A
SUBPOENA PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22,
DHfendant certifies that:
(1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was
mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to
be! served;
(2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate;
(3) no objection to the subpoena has been received, and
(4) the subpoena which will be served is identical to the subpoena which is attached to the notice
of intent to serve the subpoena.
Date: September 20, 2002
JOHNSON, DUFFIE, STEWART & WEIDNER
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,I Johnson, Duffie, Stewart & Weidner
By: Melissa Peel Greevy
1.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2203 CIVIL TERM
WENDY L. VANSCYOC,
v.
CIVIL ACTION - LAW
MIGHAEbS.-VANSCYOC,
IN DIVORCE
Defendant
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
TO: Michael S. VanSycoc
cia Max J. Smith, Jr., Esquire
James, Smith, Durkin & Connelly
P.O. Box 650
Hershey, PA 17033
Defendant intends to serve a subpoena identical to the one that is attached to this notice. You have
twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an
objection to the subpoena. If 110 objection is made, the subpoena may be served.
Date: May 22, 2002
JOHNS~, STEWART & WEIDNER
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. issa Peel Greevy
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2203 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WENDY L. VANSCYOC,
v.
MICHAEL S. VANSCYOC,
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
TO: Attn: Pension Dept.
AETNA Investment Services, LLC
c/o ING Life Insurance and Annuity Company
151 Farmington Avenue TN21
Hartford, CT 06156
Within twenty (20) days after service of this subpoena, you are ordered by the Court to produce the
following documents or things: Copies of any and all documents relating to investments, 401 (k) plans, or
annuities of the Defendant, Michael S. VanScyoc, SS# 188-68-1190, at 301 Market Street, Lemoyne, PA
17043.
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certificate of compliance, to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days after
its service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
Melissa Peel Greevy, Esquire
301 Market Street
Lemoyne. PA 17043
(717) 761-4540
Supreme Court 10 No. 77950
Attorney for Plaintiff
BY THE COURT:
Prothonotary/Clerk, Civil Division
Date:
Seal of the Court
Deputy
:158491-2
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Johnson, Duffie, Stewart & Weidner
By: Melissa Peel Greevy
LD. No. 779S0
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2203 CIVIL TERM
WENDY L. VANSCYOC,
v.
CIVIL ACTION - LAW
MICHAEL S. VANSCYOC,
IN DIVORCE
Defendant
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NOTICE .- "'O:l:
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If you wish to deny any of the statements set forth in this affidavit, you must file ~
within twenty days after this affidavit has been served on you or the statements will be ~~t
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AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
1. The parties to this action separated on February 27, 2000 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. !l4904 relating to unsworn falsification
Date:f;1tIL '7; 2603
to authorities.
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CERTIFICATE OF SERVICE
AND NO\lll, this $dV day of April , 2003, the undersigned does hereby certify that she did this date
sen/e a copy of the foregoing Affidavit Under Section 3301 (d) of the Divorce Code upon the Defendant and his
counsel causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne,
Pennsylvania, addressed as follows:
Max J. Smith, Jr. Esquire
P. O. Box 650
Hershey, PA 17033
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Johnson, Duffie, Stewart & Weidner
By: Melissa Peel Greevy
1.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4S40
Attorneys for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2203 CIVIL TERM
WENDY L. VANSCYOC,
v.
CIVIL ACTION - LAW
MICHAEL S. VANSCYOC,
IN DIVORCE
Defendant
PRAECIPE TO WITHDRA W COUNT /I OF COMPLAINT IN DIVORCE
TO THE PROTHONOTARY:
Please withdraw Count II only of Plaintiff's Complaint in Divorce filed on April 11 , 2000.
Respectfully submitted,
Date: April 30, 2003
STEWART & WEIDNER
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CERTIFICA TE OF SERVICE
AND NOW, this 30th day of April , 2003, the undersigned does hereby certify that she did this date
serve a copy of the foregoing Praecipe upon the Defendant and his counsel causing same to be deposited in
the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows:
Max J. Smith, Jr. Esquire
P. O. Box 650
Hershey, PA 17033
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Johnson, Duffie, Stewart & Weidner
By: Melissa Peel Greevy
LD. No. 77950
30 I Market Street
P. O. Box 109
Lemoyne, Pennsylvania I 7043-0 I 09
(717) 761-4540
Attorneys for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-2203 CIVIL TERM
CIVIL ACTION - LAW
WENDY L. VANSCYOC,
v.
MICHAEL S. VANSCYOC,
IN DIVORCE
Defendant
Notice is hereby given that the Plaintiff in the above matter, having been granted a final Decree in
Divorce on the ih day of May, 2003, hereby intends to resume and hereafter use the previous name of
WENDY L. MERRIS and gives this written notice avowing her intention in accordance with the provisions of
the Act of December 16,1982, P.L. 1309 No. 295, ~702; 54 Pa.C.S.A. 704, as amended.
~~
TO BE KNOWN AS:~
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COMMONWEALTH OF PENNSYLVANIA
ss:
COUNTY OF CUMBERLAND
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On this, the 7 day of. , 2003, before me. a notary public, personally
appeared WENDY L. VANSCYOC, known to e to be the person whose name is subscribed to the within
document and acknowledged that she executed the foregoing for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
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Kristee K. MyeIS, Notary Public
I.ernoyne Boro, ClJmberland County
My Commission ElcpiIea Dec. 2, 2006
Member, Pennsylvania A88ooIa1Ion 01 NolIrfII
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