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HomeMy WebLinkAbout07-0970 SHERRY J. KRAMER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. c) - q7D RAY E. KRAMER, ?t u t (, ?J2..?1 Defendant 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 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office, Cumberland County Courthouse, Cumberland, 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 2 Liberty Avenue Carlisle, PA 17013 (800) 990-9108 4 SHERRY J. KRAMER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. U? RAY E. KRAMER, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, SHERRY J. KRAMER, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE, and seeks to obtain a Decree in Divorce from the above-named Defendant, RAY E. KRAMER, upon the grounds hereinafter set forth: 1. Plaintiff is SHERRY J. KRAMER, an adult individual, residing at 814 Bridge Street, New Cumberland, Cumberland County, Pennsylvania. 2. Defendant is RAY E. KRAMER, an adult individual, residing at 264 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 30, 2004 in Dillsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of United States of America. 7. The Defendant is not a member of the Armed Services of the United States. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that she may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff, SHERRY J. KRAMER, respectfully requests this Honorable Court to enter a Decree in Divorce pursuant to the Divorce Code. Respectfully submitted, DATED: Robert B. Lieberman, Esquire 500 N. Third Street, 12th Floor Harrisburg, PA 17101 (717) 236-1485 Attorney for Plaintiff I N VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. 1-aa-07 Qs?w Dated Sherry J. Kr 0e,4 Plaintiff ccl 1f1 us 0 SHERRY J. KRAMER, Petitioner V. RAY E. KRAMER, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-970 Civil Term IN DIVORCE PETITION FOR SPECIAL RELIEF PREVENTING THE DISPOSITION OF PROPERTY PURSUANT TO THE DIVORCE CODE AND Pa R.C P 1920.43(a) AND NOW, this ?/g day of February, 2007, comes Petitioner, SHERRY J. KRAMER, by and through her attorney, Robert B. Lieberman, Esquire, and in support of the within Petition avers and states as follows: 1. That Petitioner, SHERRY J. KRAMER, is an adult individual, residing at 814 Bridge Street, New Cumberland, Cumberland County, Pennsylvania. 2. That Respondent, RAY E. KRAMER, is an adult individual, residing at 264 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. That Petitioner, SHERRY J. KRAMER, and Respondent, RAY E. KRAMER, separated on or about December 11, 2006. 4. That Petitioner, SHERRY J. KRAMER, filed a Complaint in Divorce docketed to the above number and term in the Prothonotary's Office of Cumberland County on February 20, 2007. A copy of which is attached hereto and marked Exhibit "A". 5. That Petitioner, SHERRY J. KRAMER, filed a Petition for Related Claims docketed to the above number and term in the Prothonotary's Office of Cumberland County on February 28, 2007. A copy of which is attached hereto and marked Exhibit "B". 6. That Respondent, RAY E. KRAMER, is the owner of the marital residence located at 264 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania. 7. That the aforesaid residence is marital property pursuant to the Divorce Code. That the value of the marital residence is in excess of Three Hundred Thousand ($300,000.00) Dollars. 9. That Petitioner, SHERRY J. KRAMER, has reason to believe that Respondent, RAY E. KRAMER, is in the process of selling the property and may dispose of the proceeds by using the funds for his personal use. 10. That by liquidating the aforesaid proceeds of sale, Respondent, RAY E. KRAMER, will wrongfully, intentionally and maliciously prevent Petitioner, SHERRY J. KRAMER, from exercising her rights and will defeat her claim for equitable distribution of the marital asset. 11. That immediate and irreparable harm will be caused to Petitioner, SHERRY J. KRAMER, if Respondent, RAY E. KRAMER, is not enjoined from liquidating the proceeds from the sale of the marital asset. WHEREFORE, Petitioner, SHERRY J. KRAMER, respectfully requests equitable relief as follows: a. That this Honorable Court issue an Order enjoining Respondent, RAY E. KRAMER, from disposing, transferring, encumbering, concealing, selling, liquidating, removing or alienating the proceeds from any sale in whole or in part; b. That this Honorable Court issue an Order requiring an accounting of any sale proceeds by Respondent, RAY E. KRAMER, so a fair and equitable distribution of this marital asset can be disbursed to the parties through the pending divorce action. C. That this Honorable Court attach any proceeds from the sale of the aforesaid asset. d. That this Honorable Court grant Petitioner, SHERRY I KRAMER, attorneys fees, costs and expenses. e. That this Honorable Court grant such other relief as the Court deems just and reasonable. Respectfully Submitted, Dated: Q , - Robert B. Lieberman, Esquire 500 N. Third Street, 12th Floor Harrisburg, PA 17101 (717) 236-1485 Attorney for Petitioner SHERRY J. KRAMER, Plaintiff V. RAY E. KRAMER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CI VIL ACTION - LAW NO. 0 -7 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 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office, Cumberland County Courthouse, Cumberland, 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. c? o Cumberland County Bar Association 2 Liberty Avenue `` ' r"? Carlisle PA 17013 >- o (800) 990-9108 J Cn ECHISIT,W"A; SHERRY J. KRAMER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. RAY E. KRAMER, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, SHERRY J. KRAMER, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE, and seeks to obtain a Decree in Divorce from the above-named Defendant, RAY E. KRAMER, upon the grounds hereinafter set forth: Plaintiff is SHERRY J. KRAMER, an adult individual, residing at 814 Bridge Street, New Cumberland, Cumberland County, Pennsylvania. 2. Defendant is RAY E. KR.AMER, an adult individual, residing at 264 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 30, 2004 in Dillsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of United States of America. 7. The Defendant is not a member of the Armed Services of the United States. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that she may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff, SHERRY J. KRAMER, respectfully requests this Honorable Court to enter a Decree in Divorce pursuant to the Divorce Code. Respectfully submitted, DATED: 6-7 B Robert B. Lieberman, Esquire 500 N. Third Street, 12th Floor Harrisburg, PA 17101 (717) 236-1485 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. 7-aa -0~7 Dated Sherry J. Kr e , Plaintiff SHERRY J. KRAMER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW :NO. 07-970 Civil Term RAY E. KRAMER, Defendant : IN DIVORCE PETITION FOR RELATED CLAIMS UNDER DIVORCE CODE The petition of SHERRY J. KRAMER, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE, respectfully represents that: 1. Petitioner is the Plaintiff in the above-captioned divorce matter. 2. Plaintiff and Defendant have acquired property, during their marriage until the date of their separation, which property is marital. 3. Plaintiff requests this Court to preserve her right to have all marital property of the parties equitably distributed. 4. Plaintiff lacks sufficient property to provide for her reasonable needs, is unable to adequately support herself through appropriate employment and to pay obligations which were in existence at the time of the parties' separation. 5. Plaintiff requires reasonable support to adequately maintain herself and to pay the obligations existing at the time of the parties' separation. EXHIBIT "BH 6. Plaintiff requests this Court to preserve her right to seek an award of alimony pendente lite and/or financial assistance to pay existing and future obligations and to award alimony following a Decree in Divorce. 7. Plaintiff has employed Robert B. Lieberman, Esquire as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 8. Plaintiff requests the Court to allow her equitable distribution of marital property, reasonable counsel fees, costs and expenses and alimony pendente lite pursuant to the Divorce Code and Rules of Civil Procedure and at final hearing to further award alimony and such additional sums as are deemed appropriate. WHEREFORE, Petitioner prays that your Honorable Court to preserve her claims for equitable distribution of marital property, alimony pendente lite, alimony, counsel fees, costs and expenses. Respectfully submitted, DATED: Robert B. Lieberman, Esquire 500 N. Third Street, 12th Floor Harrisburg, PA 17101 (717) 236-1485 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Petition for Related Claims are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated jSh?e5rrryjJ. Kr er Plaintiff SHERRY J. KRAMER, : IN THE COURT OF COMMON PLEAS Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 07-970 Civil Term RAY E. KRAMER, Respondent : IN DIVORCE CERTIFICATE OF SERVICE I, Robert B. Lieberman, Esquire, attorney for Petitioner, SHERRY J. KRAMER, hereby certify that a true and correct copy of the Petition for Related Claims in the above captioned matter was mailed to Respondent, RAY E. KRAMER by certified and first class mail at Harrisburg, Pennsylvania on February 27, 2007 addressed as follows: Ray E. Kramer 264 Ridge Hill Road Mechanicsburg, PA 17050 Robert B. Lieberman, Esquire 500 North Third Street, 12th Floor P.O. Box 1004 Harrisburg, PA 17108-1004 Attorney for Petitioner VERIFICATION I verify that the statements made in the foregoing Emergency Petition for Special Relief are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. .9, ' .Z 7 . a 7 Dated erry J. Kr Plaintiff/Petiti ler SHERRY J. KRAMER, : IN THE COURT OF COMMON PLEAS Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 07-970 Civil Term RAY E. KRAMER, Respondent : IN DIVORCE CERTIFICATE OF SERVICE I, Robert B. Lieberman, Esquire, attorney for Petitioner, SHERRY J. KRAMER, hereby certify that a true and correct copy of the Petition for Special Relief in the above captioned matter was mailed to Respondent, RAY E. KRAMER by certified and first class mail at Harrisburg, Pennsylvania on February 27, 2007 addressed as follows: Ray E. Kramer 264 Ridge Hill Road Mechanicsburg, PA 17050 Q, . Robert B. Lieberman, Esquire 500 North Third Street, 12th Floor P.O. Box 1004 Harrisburg, PA 17108-1004 Attorney for Petitioner C ? . ? ? ? .rl W ? -j . ?' ..R-.p ` ? L'?? ? .rye ? y? 4 .?. ? f 4 SHERRY J. KRAMER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 07-970 Civil Term RAY E. KRAMER, : Defendant : IN DIVORCE PETITION FOR RELATED CLAIMS UNDER DIVORCE CODE The petition of SHERRY J. KRAMER, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE, respectfully represents that: Petitioner is the Plaintiff in the above-captioned divorce matter. 2. Plaintiff and Defendant have acquired property, during their marriage until the date of their separation, which property is marital. Plaintiff requests this Court to preserve her right to have all marital property of the parties equitably distributed. 4. Plaintiff lacks sufficient property to provide for her reasonable needs, is unable to adequately support herself through appropriate employment and to pay obligations which were in existence at the time of the parties' separation. Plaintiff requires reasonable support to adequately maintain herself and to pay the obligations existing at the time of the parties' separation. A 6. Plaintiff requests this Court to preserve her right to seek an award of alimony pendente lite and/or financial assistance to pay existing and future obligations and to award alimony following a Decree in Divorce. 7. Plaintiff has employed Robert B. Lieberman, Esquire as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 8. Plaintiff requests the Court to allow her equitable distribution of marital property, reasonable counsel fees, costs and expenses and alimony pendente lite pursuant to the Divorce Code and Rules of Civil Procedure and at final hearing to further award alimony and such additional sums as are deemed appropriate. WHEREFORE, Petitioner prays that your Honorable Court to preserve her claims for equitable distribution of marital property, alimony pendente lite, alimony, counsel fees, costs and expenses. Respectfully submitted, DATED: Robert B. Lieberman, Esquire 500 N. Third Street, l fh Floor Harrisburg, PA 17101 (717) 236-1485 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Petition for Related Claims are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. -?- , .2, 7 . 07 Dated S??qol ? Sherry I Kr er Plaintiff H SHERRY J. KRAMER, : IN THE COURT OF COMMON PLEAS Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 07-970 Civil Term RAY E. KRAMER, Respondent : IN DIVORCE CERTIFICATE OF SERVICE I, Robert B. Lieberman, Esquire, attorney for Petitioner, SHERRY J. KRAMER, hereby certify that a true and correct copy of the Petition for Related Claims in the above captioned matter was mailed to Respondent, RAY E. KRAMER by certified and first class mail at Harrisburg, Pennsylvania on February 27, 2007 addressed as follows: Ray E. Kramer 264 Ridge Hill Road Mechanicsburg, PA 17050 Robert B. Lieberman, Esquire 500 North Third Street, 12"' Floor P.O. Box 1004 Harrisburg, PA 17108-1004 Attorney for Petitioner N Q> hC ?:- ?S SHERRY J. KRAMER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW NO. 07-970 CIVIL TERM RAY E. KRAMER, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, ROBERT B. LIEBERMAN, ESQUIRE, who, being duly sworn according to law, deposes and says: 1. That on February 20, 2007, a Complaint in Divorce was filed on behalf of Plaintiff and against Defendant in the above case. 2. ` That on February 22, 2007, I forward by certified mail, return receipt requested, restricted delivery, a certified copy of the Complaint in Divorce to Defendant, RAY E. KRAMER, 264 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. That the aforesaid copy of the Complaint in Divorce sent to Defendant, RAY E. KR.AMER, was delivered on February 23, 2007, as evidenced by the return receipt card signed by Defendant and attached hereto. 4. That to the best of my information and belief, the signature on the return receipt card is, in fact, the signature of Defendant, RAY E. KRAMER. ?I Robert& Lieberman, Esquire Attorney for Plaintiff SWORN to and subscribed before me this day of February, 2007. Not Public My Commission Expires: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL NANCY H. ALGER, Notary Public City of Harrisburg, Dauphin County My Commission Expires Feb. 17, 2010 I ERTIFIED MAIL RECEiN T ;Domestic Mail Only; No Insurance Coverage Provided) r Vor delivery information visit our website at www.usps.com 2 1 USE 0 Postage $ 3 -I' Certified Fee n U C V C3 Return Receipt Fee / Postmark O (Endorsement Required) ? l , Reetdcted Delivery Fee (Endorsement Required) O M1 Total Postaae & Fees .4t () . C; rU Sent To S-----treet,-A-------------------------- No.; or PO Box No. a---y bid._ c_l-i.a..J.jo.4,d - -------- City, R .0 O O !ti f1 C3 .o ,A M M C3 0 c a 0 C3 -0 N rU -0 0 0 M1 1l', i c rrl . co _, w FEB $ 8 2007x4 SHERRY J. KRAMER, : IN THE COURT OF COMMON PLEAS Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 07-970 Civil Term RAY E. KRAMER, Respondent : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this day of IM v A , 2007, upon review and consideration of the attached Petition for Special Relief, a Rule is hereby issued upon Respondent, RAY E. KRAMER, to show cause as to why the request of Petitioner, SHERRY J. KRAMER, should not be granted. Rule returnable 7 days from the date of service. Distribution: Robert B. Lieberman, Esq., 500 N. 3`d St., 12t Fl., P.O. Box 1004., Harrisburg, PA 17108-1004 Ray E. Kramer, Respondent, 264 Ridge Hill Road, Mechanicsburg, PA 17050 BY THE COURT: EL LU ?i Q CJ SHERRY J. KRAMER, Petitioner V. RAY E. KRAMER, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-970 Civil Term IN DIVORCE MOTION FOR CONFERENCE ry*L AND NOW, this b ' day of P4 , 2007, comes Petitioner, SHERRY J. KRAMER, by and through her attorney, Robert B. Lieberman, Esquire and in support of the within Motion avers and states as follows: 1. That Petitioner, SHERRY J. KRAMER, is an adult individual, residing at 814 Bridge Street, New Cumberland, Cumberland County, Pennsylvania. 2. That Respondent, RAY E. KRAMER, is an adult individual, residing at 264 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. That Petitioner, SHERRY J. KRAMER, filed a Complaint in Divorce docketed to the above number and term in the Prothonotary's Office of Cumberland County on February 20, 2007. 4. That Petitioner, SHERRY J. KRAMER, filed a Petition for Related Claims docketed to the above number and term in the Prothonotary's Office of Cumberland County on February 28, 2007. 5. That Petitioner, SHERRY J. KRAMER, filed a Petition for Special Relief docketed to the above number and term in the Prothonotary's Office of Cumberland County on February 28, 2007. 6. That the Honorable J. Wesley Oler, Jr., issued a Rule to Show Cause on March 1, 2007 returnable in seven (7) days from the date of service. A copy of the Rule is attached hereto and marked Exhibit "A". 7. That a copy of the Rule to Show Cause was mailed to Respondent, RAY E. KRAMER, by the Court Administrator of Cumberland County and Petitioner's counsel, Robert B. Lieberman, Esquire on March 6, 2007. 8. That Respondent, RAY E. KRAMER, has failed to respond to the Rule to Show Cause within the required seven (7) days. 9. That Petitioner, SHERRY J. KRAMER, requests this Honorable Court to schedule a hearing on the Petition for Special Relief. WHEREFORE, Petitioner, SHERRY J. KRAMER, respectfully requests this Honorable Court to enter an Order scheduling a hearing in the above matter. Dated: A4AA-0-? 21a , 2007 Respectfully submitted, Robert B. Lieberman, Esquire 500 N. Third Street, 12'h Floor P.O. Box 1004 Harrisburg, PA 17108-1004 (717) 236-1485 Attorney for Petitioner FEB 1 8 20074Y SHERRY J. KRAMER, Petitioner V. RAY E. KRAMER, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-970 Civil Term IN DIVORCE RULE TO SHOW CAUSE MAR 0 5 2007 B Y: -------------------- - 2007, upon ANID NOW, this 14,f, day of `h4 4, review and consideration of the attached Petition for Special Relief, a Rule is hereby issued upon Respondent, RAY E. KRAMER, to show cause as to why the request of Petitioner, SHERRY J. KRAMER, should not be granted. Rule returnable '7 days from the date of service. BY THE COURT: J. Distribution: Robert B. Lieberman, Esq., 500 N. 3`d St., 12t Fl., P.O. Box 1004., Harrisburg, PA 17108-1004 Ray E. Kramer, Respondent, 264 Ridge Hill Road, Mechanicsburg, PA 17050 To?ttmony 1?rir?:. q,?: ?. ??to set my r?:.4c d the Wal of saiO J?wt at Carte, Pa. EXHIBIT "Au 9Ii& day /0nt/''1?- / a. r,. VERIFICATION I verify that the statements made in the foregoing Motion for Hearing are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. P? Dated RLieberman, Esquire, Attorney for Petitioner, Sherry J. Kramer SHERRY J. KRAMER, Petitioner V. RAY E. KRAMER, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-970 Civil Term IN DIVORCE CERTIFICATE OF SERVICE I, Robert B. Lieberman, Esquire, attorney for Petitioner, SHERRY J. KRAMER, do hereby certify that a copy of the Motion for Hearing, in the above matter, was mailed to Respondent, RAY E. KRAMER, on March 28, 2007, by depositing same in the United Stated Mail, postage pre-paid at Harrisburg, Pennsylvania addressed as follows: Ray E. Kramer 264 Ridge Hill Road Mechanicsburg, PA 17050 J.4_4? z Dated Robert B. Lieberman, Esquire 500 North Third Street, 12?h Floor P.O. Box 1004 Harrisburg, PA 17108-1004 Attorney for Petitioner ra O ?J ? SHERRY J. KRAMER, Petitioner V. RAY E. KRAMER, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-970 CIVIL TERM ORDER OF COURT AND NOW, this 2nd day of April, 2007, upon consideration of Petitioner's Petition for Special Relief and Motion for Conference, a hearing is scheduled for Tuesday, May 29, 2007, at 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, J esley Oler, r., J. VKlobert B. Lieberman, Esq. P.O. Box 1004 Harrisburg, PA 17108-1004 Attorney for Petitioner V161y E. Kramer 264 Ridge Hill Road Mechanicsburg, PA 17050 Respondent, pro Se rc J ? ?O OOl 9C :C P"d Z- 1,1.8V LOOZ 3Hi 114 SHERRY J. KRAMER, Plaintiff V. RAY E. KRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 07-970 CIVIL ACTION IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned, Joseph D. Caraciolo, Esquire, and Foreman & Foreman, P.C. on behalf of the Defendant, Ray E. Kramer, in the above captioned civil action. itted Date: C 13 ?' 7 Y ph D. CaracioTo, Esquire REMAN & FOREMAN, P.C. 12 Market Street, 6th Floor Harrisburg, PA 17101 ID: 90919 TEL: (717)236-9391 ?? ='cti ??' ? e F ..-+ r 5?' ?-4 .?,,"' p,e :-?. _. ?; i SHERRY J. KRAMER, Petitioner V. RAY E. KRAMER, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-970 CIVIL TERM ORDER OF COURT AND NOW, this 30th day of May, 2007, upon consideration of the attached letter from Robert B. Lieberman, Esq., attorney for Petitioner, the hearing previously scheduled for May 29, 2007, is continued generally. The parties are requested to notify the court if a hearing is desired in this matter or if a settlement is reached. BY THE COURT, J. esley Oler, Jr., /Obert B. Lieberman, Esq. P.O. Box 1004 Harrisburg, PA 17108-1004 Attorney for Petitioner V/- eph D. Caraciolo, Esq. eterans Building 112 Market Street Sixth Floor Harrisburg, PA 17101 Attorney for Respondent :rc Lz .Z a a? ? a WOO 1oJjo 40 IV ROBERT B. LIEBERMAN ATTORNEY AT LAW Five Hundred North Third Street Twelfth Floor P. O. Box 1004 Harrisburg, Pennsylvania 17108-1004 (717) 236-1485 FAX (717) 236-7777 May 29, 2007 The Honorable J. Wesley Oler, Jr. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 In re: Kramer v. Kramer No. 07-970 Civil Term Dear Judge Oler: File No. 0052-1 This letter is in follow up to a phone conversation with your secretary last week concerning my request for a general continuance in connection with the matter scheduled for hearing on Tuesday, May 29, 2007. The Respondent, Ray E. Kramer, has recently retained counsel and we are now in the process of attempting to negotiate an overall settlement of this matter. Mr. Kramer's attorney is Joseph D. Caraciolo, Esquire. His office is located at the Veterans Building, 112 Market Street, Sixth Floor, Harrisburg, Pennsylvania, 17101. Thank you very much for your cooperation in connection with this matter. Very truly yours, Q Robert B. Lieberman RBL/shy cc: Sherry J. Kramer Joseph D. Caraciolo, Esquire 0 ,?p1 SHERRY J. KRAMER, Plaintiff V. RAY E. KRAMER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-970 Civil Term CIVIL ACTION -LAW IN DIVORCE PETITION FOR SPECIAL RELIEF IN THE FORM OF EXCLUSIVE POSSESSION OF THE MARITAL RESIDENCE PURSUANT TO 23 Pa.C.S. & 3502(c) OF THE DIVORCE CODE AND NOW, comes the Defendant, Ray E. Kramer, by and through his attorneys, Foreman, Foreman & Caraciolo, P.C., and files this Petition pursuant to rule 1920.43 of the rules of Civil Procedure and 23 Pa.C.S.§3323 (f) and 23 Pa.C.S. §3502 (f), and respectfully avers as follows: 1. Plaintiff is Sherry J. Kramer, an adult individual, who currently resides at, 814 Bridge Street, New Cumberland, Cumberland County, Pennsylvania. 2. Defendant is Ray E. Kramer, an adult individual, who currently resides at 264 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. The parties to this matter were married on April 30, 2004. 4. A Divorce Complaint was filed on February 20, 2007, with docket number captioned above. 5. The parties have lived separate and apart since Plaintiff abandoned Defendant in December of 2006. 6. The subject property in this matter is 264 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania, which, by Deed dated July 17, 1992 was transferred to the Defendant. 7. At all times relevant to this action, Defendant has resided in the residence and has resided there without the presence of the Plaintiff both before the date of marriage and after the date of separation. 8. In December 2006, Plaintiff removed herself from Defendant's residence and established her own residence. 9. When Plaintiff removed herself from Defendant's residence, she took personal property, including marital property, without the permission or consent of the Defendant. 10. Recently, Plaintiff has been entering Defendant's property, frequently at times when Defendant has been unavailable. 11. During the times Plaintiff is on Defendant's property, she frequently causes a disruption to Defendant's farming business and Defendant's well-being as, often, Plaintiff is visibly intoxicated. 12. On Sunday, August 10, 2008, Plaintiff's son entered Defendant's property and removed unknown items belonging to Defendant and a third party without the consent of Defendant or the third party owner. 13. Defendant is cooperating with local police authority in the investigation and prosecution of Plaintiff's son for removing said items. 14. It is believed and therefore averred that Plaintiff sent her son to Defendant's residence to remove said items. 15. Plaintiff's actions in sending her son to Defendant's property has caused disruption in Defendant's life and business. 16. Defendant is concerned that Plaintiff will continue her course of conduct and attempt to remove more property, or cause more disturbance to Defendant. SHERRY J. KRAMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-970 Civil Term RAY E. KRAMER CIVIL ACTION -LAW Defendant IN DIVORCE ATTORNEY VERIFICATION The undersigned, Joseph D. Caraciolo, Esquire, hereby verifies and states that: 1. He is the attorney for the Defendant, Ray E. Kramer; 2. He is authorized to make this verification on his behalf; 3. The facts set forth in the foregoing Motion are known to him and not necessarily to his client; 4. The facts set forth in the foregoing Motion are true and correct to the best of his knowledge, information and belief; and 5. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: J#eph D. Caraciol65-Esquire 12 Market Street, 6t' Floor Harrisburg, Pennsylvania 17101 Telephone: (717) 236-9391 Attorney ID: 90919 Attorney for Plaintiff 17. Plaintiff has the means to support herself and to maintain a home outside Defendant's residence without the help of the Defendant. 18. According to Cumberland County local rule 208.2 (d), counsel for Defendant spoke with counsel for Plaintiff on August 12, 2008 who indicated that he does not concur with this request. WHEREFORE, the Defendant, Ray E. Kramer, respectfully requests that this Honorable Court enter an Order for Equitable Relief as follows: That Defendant is granted exclusive possession of the residence located at 264 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania and the Plaintiff be prohibited from entering the residence without the specific written permission of the Defendant. Date: kea e J seph D. Qafaciolb, Esquire 12 Market Street, 6th Floor Harrisburg, Pennsylvania 17101 Telephone: (717) 236-9391 Attorney ID: 90919 Attorney for Defendant SHERRY J. KRAMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-970 Civil Term RAY E. KRAMER CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify I am this day serving a copy of the Petition attached hereto, upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by mailing a copy of the same, United States First Class mail, prepaid, and addressed as follows: Robert B. Lieberman, Esquire 500 North Third Street P.O. Box 1004 Harrisburg, PA 17108-1004 Date: l'y ?? fo ph D. Caraciolo, 9squire 1 2 Market Street, 6' Floor arrisburg, Pennsylvania 17101 elephone: (717) 236-9391 Attorney ID: 90919 Attorney for Plaintiff a r f YI? SHERRY J. KRAMER, IN THE COURT OF COMMON PLEAS OF Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW RAY E. KRAMER, Respondent NO. 07-970 CIVIL TERM ORDER OF COURT AND NOW, this 18'h day of August, 2008, upon consideration of Defendant's Petition for Special Relief in the Form of Exclusive Possession of the Marital Residence Pursuant to 23 Pa. C.S. §3502(c) of the Divorce Code, a hearing is scheduled for Monday, October 20, 2008, at 3:00 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. ertB. Lieberman, Esq. P.O. Box 1004 Harrisburg, PA 17108-1004 Attorney for Plaintiff XJose h D. Caraciolo, Esq. , ans Buil ding Market Street Sixth Floor Harrisburg, PA 17101 Attorney for Defendant J :rc BY THE COURT, _a SHERRY J. KRAMER, Petitioner V. RAY E. KRAMER, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-970 CIVIL TERM IN RE: DEFENDANT'S PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 16`h day of October, 20089, upon consideration of the attached letter from Joseph D. Caraciolo, Esq., attorney for Defendant, the hearing previously scheduled for October 20, 2008, is CONTINUED GENERALLY. Counsel are directed to motion the Court if a hearing in this matter is required or when a settlement has been reached. BY THE COURT, obert B. Lieberman, Esq. P.O. Box 1004 Harrisburg, PA 17108-1004 Attorney for Plaintiff oseph D. Caraciolo, Esq. Veterans Building 112 Market Street Sixth Floor Harrisburg, PA 17101 Attorney for Defendant :rc n Wesley Oler, A ? 4 _c Wd 9 ! 130 OOOZ 3?a JO aoti4o- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ` ov:l 60' Plaintiff Vs . File No. 07. 110 IN DIVORCE a1- Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree-.n Divorce, or after the entry of a Final Decree in Divorce dated , hereby elects to resume the prior surname of and gives this f 54 P.S. 704. written not'ce vowin his / her intention pur7ZZV2A?yj) Date: f ? Signature cIfnalpe being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF 6U `/ hd) On the P? day of jdL4LM1r , 2008, before me, the Prothonotary or the 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 he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 Notary Public r , RID?FICE ?/ OF THE/?qF"1'? 2009 DEC -8 AM 10: 13 PENNS` LVANA SHERRY .I. KRAMER, IN TI-[E COURT OF COMMON PLEAS Plaintiff CUMl3ERLAND COUNTY. PENNSYI.vANtA~, ~ . :CIVIL ACTION -LAW NO. 07-0970 RAY E , KRAMER, ~" Defendant IN D:[VORCE ~ ~ ~ ~ .~ STATEMENT OF INTENTION TO PROCEED TO THE PROTHONOTARY: On behalf of the Plaintiff, SHERRY J. KRAMER, please note that we are intending to proceed with the Complaint in Divorce docketed to the above number :md term. D~-te Robert B. Lieberman, Esquire 1'.007 Mumma. Road, Suite 1 ~~ I Lemoyne, PA 17043 717-236-1485 Attorney for Plaintiff