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Home My WebLink About97-02717 c-l L. ~ c .... - -0 ~ . -; ~ .C - - - e r ~ j r- - r- (() I t- O"! .1 Z ,.; \ \ / ,~ ~ ',' ~ '.' ~ ',' ~ ,', ~ .' ~ ~ ',' ~ '.' ~l '.' w ~.. t, ,', ~ ~ s .,' ~ ~ '.' ~ ~ ~ '.' s ~ ~ ~ .' ~ ~. ~ ~, ~ '.' ~*~*~~~~~~-~~~~****~)~~;-~-*~~-~~~ l. ---. ----- '''-'''- -------......-..--...... _.......................... ___ ~ ~ ~.' ~ "'\ ~I ".l ~l .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF 1~~ PENNA, ."-'~~.I-,'.T s ~ ',' ~/ ',' ~ ',' ~ '.' JOEL EMERSON TROLINGER, Plaintiff,.. N ll. .?717,..,....... ....,............ II) 97 ~ Vl'l':HIS KATH~E SQE TROLINGER, . . . I Defendant DECREE IN ANDNOW,pJ~~~~~'~~p it is ordered and decreed that... JD.al. Emerso.n .Tro.l1nge.r..,...........,....., plaintiff. and. .... .. .. ,ICAtb!Il..SUIl. .'r.l:oH.ngllr.. . , . .. . . . . .. . . .. . . . . . " 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; ~'\)\\O .......... .~I)t;l. !'I.~r:~~.a.~ .~!l.tY!.!l!D.e.I)~. ,A.gr:\l!l.m.l!l)to. .~l!j;1"Il.e.l). to.h.E!.........., ~a. r.t.~t;l!l .il!. ~.e.r:eby, .~I)~!J.r.p',?~~.~,!~. !1.qj;. !D.e.r:g!l!i.......,~...........,...,. . ' I ' ,/o I ily T~~M AlIe.l: C4~ y(', x4. 1~i1~ 7f?tuvoa K qdtf" P'l.;{- tV ~(lrolhonoli\rY ~ ~ 7- ~ ~______.._. .. ^A.._....., .,.._ ....._..".. ~~~~~~-~****~******* ;~ :~ -:.;. -:.:- .:+:. -:6:' .:+:. .:.:. .:.:. .:t;. .:.:. .:+;. ~ ~.' ~ ',' ~ '.' .. ~ ~ '.' ,', ~ ,', to *- ',' ~ '.' ~ '.' ~ * .. * w '.' a ',' ~ !:. ~ ~ '.' w '.' ~ '.' .:' ~ ~ ~ ~ $ * * ~ $ I~ /'.' I.., i~ I~ r:' 1~ i' 1* J. . i* .~ ..~ ..... (;', , - l;T: - 1-; r:: ~ \1Jt:: - , . c...)#_' ..~ C . lJ.: -- ., <I l.>- q:' \,0 C:, \..1.\->- 1 ' " r~>. ..... ',tl -' " " .~ ,. -~.J \1. c:: :') 0 v' 0 JOEL EMERSON TROLLINGER, Plaintiff vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 97- (A717 CIVIL TERM IN DIVORCE KATHI SUE TROLLINGER, Defendant COMPLAINT IN DIVORCE NOW COMES, Plaintiff Joel Emerson Trollinger, by his attorney, John Wesley Weigel III, Esquire, to move and allege as follows: 1. Plaintiff Joel Emerson Trollinger is an adult individual residing at 1121 Rebecca Street, Carlisle, Cumberland County, Pennsylvania. 2, Defendant Kathi Sue Trollinger is an adult individual residing at 1121 Rebecca Street, Carlisle, Cumberland County, Pennsylvania. 3, Plaintiff has resided in the Commonwealth of Pennsylvania for at least six mouths immediately previous to the filing of this Complaint, 4. The Plaintiff and Defendant were married on June 25, 1993 in Hagerstown, Maryland. 5. There have been no prior actions of divorce or annulment filed in this matter. 6. The marriage is irretrievably broken, 7, Plaintiff has been advised that marriage counseling is available, and that Plaintiff may have the right to request that the court require the parties to participate in marriage counseling, WHEREFORE, Plaintiff Joel Emerson Trollinger requests the ~ 1" .- j:': C'" ,.. luf' (.~~ ' - 0" :..-r: ~~i:: i~: .... <'", 1;:1 Uj~;- c-.: dji -. ',' u. ~' .- ,.... r'" ., :...,"j lj ::: ' n. r- .. :) a' U t ~ ~~ ~ &. I~ ~ % "'1\;::) ~......~ ~ ~ ~ ~ I", '-Il ~ "" ~~ ~ >4l ~~ '.. C' ;- j:- , . ., , ., ~~ ...-:". 1 , ," '::C , , , ~.: " , ....... ..~j 0,\1 . '-, ; ,..:) r " :i ~.i ,> I " " i ..,. '~i~ . ..', . Ii] ::.j l;.'l. I -J . ~ " C~ :3 u I.......... U '", C) .~ ~~ '/ ,...:; 0;' .., t~_'C . . " ~ '- )', " ( .. . ,. -,. , ' i~_: S)I: ,.;:) ;, J (.:1 I , t~. , .' ;.;. " -- n: " I ':.I ::J j' -, ...-. .~ II, m ~i () u"\ U >- Cl o- r r- , .,..... I::: to , - ,.,(".. , : LJ - . l:~ , ,,", , , cj , 1:-: , C: '.:) . l'4' I ~.;; . _..1 ',;ftJ , ! .. ~...:.) 1 .~ . -J .c , e.~ ;.:; l.) c:.' () >: II' - C' ~ ,-' , .' .'~' l.!..! ~ - , 0' , u:. '-, : ~~' ,!". ,:--..,j '~ .7'~.J ,/) . jL I ",' :-11~ . -. .liD u. ' ::.;.; :.l. j'::; -, I'" r- ::, 0 0' (J JOEL EMERSON TROLINGER, Plaintiff vs, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 97-2717 KATHIE SUE TROLINGER, Defendant IN DIVORCE PETITION FOR SPECIAL RELIEF PURSUANT TO PA.R.C.P. 1920,43 AND NOW, comes the Defendant, Kathie Sue Trolinger by her attorney, Dale F, Shughart, Jr., Esquire and represents as follows: 1. The Petitioner, Kathie Sue Trolinger, is the Defendant in the above captioned divorce action, 2, The Respondent, Joel Emerson Trolinger, is the Plaintiff in the above captioned divorce action, 3. Pursuant to a verbal agreement of the parties the Respondent, husband, has been residing at the parties' marital home located at 1121 Rebecca Street, Carlisle, North Middleton Township, Cumberland County, Pennsylvania, 4, The agreement of the parties was predicated upon the Respondent/Husband's paying the parties' two mortgages, the first mortgage having a monthly payment of $644 and the second having a monthly payment of $346, 5, The Respondent/Husband has not made the mortgage payments for October, November or December and refuses to make payment, The current delinquency is $3,062.00. 6, The parties' marital residence has been listed for sale through Century 21-Brenneman, now Coldwell Banker, 7, The two mortgages of the parties virtually eliminate any equity in the marital home and it is extremely unlikely that any purchaser will pay an amount which will net any sums of money in pocket to the Plaintiff or Defendant, 8, The aforementioned real estate company has agreed to accept a reduced commission upon sale of the property to insure that it can be sold without requiring a payment by the parties, 9, The Husband's default in the mortgages is ruining the Wife's credit and making it virtually impossible that the house can be sold, 10. On July 29, 1997 a Protection from Abuse Order was entered in favor of the Petitioner/Wife and against the Respondent/Husband in proceedings to 97-3269 Civil Term requiring him to stay away from her residence except for transferring custody of the parties' minor child. 11. The Petitioner/Wife has two children, a son Joel D. Trolinger, born August 10, 1992, who is the son of the Respondent/Husband and a daughter Alicia A, Green, 11 years of age, who is not the child of the Respondent/Husband. 12. The Petitioner is in a position to move to the marital residence immediately, and to make the monthly mortgage payments, assuming she receives APL and increased child support from the Respondent/Husband, 13. The Petitioner is simultaneously filing a Petition for Alimony Pendente Lite, 14. The Petitioner accepted $50 per week child support when the guidelines indicated $104 per week on the basis that the Respondent/Husband would make the mortgage payments, The Petitioner is contemporaneously filing a request for an increase in the amount of child support, 15, The Petitioner believes and therefore avers that her credit will be destroyed and any remaining equity the parties may have in their marital home eliminated, making it impossible to sell the home, unless the Petitioner is granted exclusive possession of the marital real estate, 16. Petitioner, through counsel, has requested Respondent to vacate and allow her exclusive possession, but Respondent has -2- ~, II Countrywide- 6400 Legacy Drive Piano, Tem 7S024.36~2 (214) 6CJ8.6OOO MSN PTX 33 IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS, DATE: December 02, 1997 TO: KATHIE S TROLINGER 112l REBECCA ST CARLISLE PA 17013 .Ru~l; C0UNTF.'iWIDE :;Oi'lE LOAN::; RE: Countrywide Loan No. 9541644 TAKE ACTION TO SAVE YOUR HOME FORECLOSURE The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works, If you need more information call the Pennsylvania Housing Finance Agency at 1(800)342-2397. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa, Si no comprende el contenido de esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (Pensylvania Housing Finance Agency) sin cargos al numero mencionado arriba. puedes ser elegible para un prestamo por el program llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la peridida del derecho a redimir su hipoteca, ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE, ~ PETITIONER'S ,. z' :X1IB1T YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS Your mortgage is in serious default because you have failed to pay, , ' II CountrywideGD 6400 Leg.cy Driv. Pl2no, T.... 75024,3632 (214) 608,6000 MSN PTX 33 promptly, installments of principal and interest, as required, for a period of at least sixty (60) days, The total amount of delinquency is $1974,72, That sum includes the following: lO/0l/97 thru 12/01/97 @ $637,90 $19l3.70 0/00/00 thru 0/00/00 @ $.00 $.00 2 Late Charges @ $25.76 $51.52 thru @ Late Charges @ Uncollected Late Charges $,00 Uncollected Fees $9.50 Uncollected Escrow Less Partial Payment < $.00 > T~T^~ AMOUNT DUE $1974. n Your mortgage is also in default for the following reason: You may be eligible for financial assistance that will prevent foreclo- sure on your mortgage if you comply with the provisions of the Home- owners' Emergency Mortgage Assistance Act of 1983 (the "Act"), You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of this notice. It contains an explanation of your rights, Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency, The purpose of that meeting is to attempt to work out a repayment plan, or to otherWise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a con- sumer credit counseling agency identified with this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. -2- [I Countrywide* 6<100 Legacy Drive Plana, Tem 75024.3632 (214) 608,6000 MSN PTJ( 33 The name, address and telephone number of our representative is: JILL MANDERFIELD Countrywide Funding Corp, Collections Mailing Address: P.O, Box 1022l, Van Nuys, CA, 91410 Telephone Number: 800/669-6654 The name(s) and address(es) of (a) designated consumer credit counseling agency(ies) is (are): (See attached consumer credit counseling agency list.) It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions, If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial ass btdll('~ f com the Homeowne~'!>' E",ergency MOt tgage !\.isi stdnce Fund, In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed above. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency, "Your application must be filed or postmarked, within thirty (30) days of your face-to-face meeting," "It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately and you will forfeit your eligibility for assistance." Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. "It is extremely important that your application is accurate and complete in every respect." The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application, The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105, Telephone Number (717) 780-3800 or 1-800-342-2397 (toll free number). -3- '- ;-.- c c.: , ~;. ,,: r~;. .. , [.. ., '- . , (): ("~) c. Ie L , . . tJ.. .- C.. .' 0- , L; r..;' C ~ , .~ ~ "Q 1 i ch" <::.J E c:l .~~ .... .... ~~ I"- ,~ 0- - j? '"U >- If) r-: a: ,.: " ~~: :) lLI~l C.~ ."C ( i-:-..' ...' -. (....1 ,~ ~j~::- c... ~ ~. (-1 ;.i . , ~.) (:0:'.' C-.J '. '/ L:..J!..' ~':. ..'!' , . :jtn u:. I" ..:: 'q;:... " .... ......~ I I. ce ::J 0 (" U ''"-'' 1",.../ ~. JOEL E, TROLINGER PACSES Member Number: 0338100018 4, If there are in your employment one or more additional employees whose incDmes are subject to the Order of the Court of CommDn Pleas of CUMBERLAND County fDr attachment of support, you may combine the attachment payments into a single payment to the Domestic Relations Section and separately identify the portion attributable to each obligor, 5, You must notify the DDmestic Relations Section when the defendant obligor tenninates employment and provide the Section with the emplDyee's last knDwn address and the name and address of the new employer, if known, 6, The maximum amount of the attachment shall not exceed so % of the employee's net income which is within the limits set in the Consumer Credit Protection Act, IS U,S,C, ~1673, 7, The tenn "income" as defined by law includes compensation for services, including, but not limited to, wages, salaries, fees, compensation in kind, commissions and similar items; income derived from business; gains derived from dealings in property; interest; rents; royalties, dividends, annuities; income from life insurance and endowment contracts; all fonns of retirement; pensions; income from discharge of indebtedness; distributive share of partnership gross income; income in respect of a decedent; income from an interest in an estate or trust; military retirement benefits; railroad employment retirement benefits, social security benefits; temporary and penn anent disability benefits; worker's compensation and unemployment compensation. 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