HomeMy WebLinkAbout97-06510
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IIN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 97-6SIO
CYNTHIA L, PRYOR,
Plaintiff
MICHAEL A. PRYOR,
DeCendant
: CIVIL ACTION . LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry of a
Divorce Decree:
1. Ground for divorce: irretrievable breakdown under Section (XX) 3301(c) ()
3301(d) of the Divorce Code.
2. Date and manner of service of the Complaint: I 2.. - P - q 7 by
Acceptance of Service of Defendant's counsel.
Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent and Waiver of Counseling
required by Section 3301(c) of the Divorce Code:
by Plaintiff: February 26,1999; by Defendant: {11f/atl I ,1999.
(b) (I) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of
the Divorce Code:
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(2) Date of service of the Plaintiffs Affidavit upon the Defendant:
4. Related claims pending: All claims of record have bee\l resolved and settled pursuant to
a Marital Settlement Agreement dated /rlCI'( h /. , 1999.
,
5. Date and manner of service of the notice of intention to file Praecipe to Transmit
Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the
Divorce Code:
6. Date and manner of service of Notice of Intention to file Praecipe to
Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(c)
of the Divorce Code:
undc! Section 3301(c) of the Divorce Code:
by Plaintiff': February 26,1999; by Defendant: /'r?tVc/" I
, 1999.
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or, date of execution of Waiver of Notice oflntention to Request Entry of a Divorce Decree
and, date of filing of the Waiver of Notice of Intention to Request Entry of a Divorce
o.:cree: Both Waivers are being filed simultaneously with this Praecipe.
JAMES, SMITH, DURKIN '" CONNELLY LLP
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. en - (0510 Cl.LJ) TQ;\(I\
CIVIL ACTION - LAW
IN DIVORCE
CYNTHIA L. PRYOR,
Plaintiff
MICHAEL A. PRYOR,
Defendant
NOTICE
You have been sued In Court. If you wish to defend against the clalrns set
forth In the following papers, you must take prompt action. You are warned that If
you fall to do so, the case may proceed without you and a Decrae In Divorce or
annulment may be entered against you by the Court. A judgrnent 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 ~he divorce Is Indignities or Irretrievable breakdown of the
rnarriage, you may request marriage counseling. A list of marriage counselors Is
available In the Office of the Prothonotary at the Cumberland County Court House,
One Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberland County Court House
Fourth Floor
1 Courthouse Square
Carlisle, Pennsylvania 17013
Phone: 1717) 240-6200
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY , PENNSYLVANIA
NO. '17 _ {, ~;Io (!,.;.J f:J.-
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CYNTHIA L. PRYOR,
Plaintiff
MICHAEL A. PRYOR.
Dafendant
CIVIL ACTION. LAW
IN DIVORCE
NonCE OF AVAilABILITY OF COUN~ElING
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To the Within Narned Defendant:
You have been named as the Defendant In a divorce proceeding flied In the
Court of Cornmon Pleas of Cumberland County. This notice Is to edvlse you that In
accordance with Section 3302(dl of the Divorce Code, you may request that the
Court require you and your spouse to attend marriage counseling prior to a divorce
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decree being handed down by the Court. A list of professional marriage counaelors
Is available at the Office of the Prothonotary, One Courthouse Square. 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 (201 days of the date on which you receive this notice. Failure to do
so will constitute a waiver of your right to request counseling.
Prothonotary
'\
CYNTHIA L, PRYOR,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 91. G 'no ~ IL..-
MICHAEL A. PRYOR,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301
OF THE DIVORCE CODE
1, Plaintiff Is Cynthia l. Pryor, who currently resides at 101 Easterly Drive,
Mechanlcsburg, Cumberland County, Pennsylvania 17055.
2. Defendant Is Michael A. Pryor, who currently resides at 428 Hogestown
Road, Mechanlcsburg, Cumberland County, Pennsylvania 17055.
3. Plaintiff and Defendant have been bona fide residents In the
Commonwealth for at least six months Immediately previous to the filing of this
Complaint.
4. Plaintiff and Defendal1t were rnarried on September 16, 1988, In Fairfield.
Solano County, California,
5. There have been no prior actions for divorce or annulment between the
parties.
6. The Plaintiff Is a citizen of the United States of America.
which are subJect to equitable dlatrlbutlon by this Court.
COUNT IV
CLAIM FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE
13. Plaintiff Is presently employed as a secretary with Spirit Memhant and
Grocer Inc. with a net bl-weekly wage of approximately Four Hundred Thirty-Four
($434.001 Dollars. Defendant Is employed as a Clerk with Watkins Motor Lines with
a net bl-weekly wage of approximately Eight Hundred Seventeen ($817.001 Dollars.
14. Plaintiff lacks sufficient property and Income to provide for her reasonable
needs.
COUNT V
CLAIM FOR ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES
UNDER SECTION 3702 OF THE DIVORCE CODE
15. Plaintiff does not have sufficient funds to support herself and pay the
counsel fees and expenses Incidental to this action.
16. Defendant Is full and well able to pay Plaintiff alimony pendent/J
lite. counsel fees and expenses Incidental to this divorce action.
........
WHEREFORE. the Plaintiff requests the Court to enter a DlIcree:
a. dissolving the marriage between the Plaintiff and Defendant;
b. equitably distributing all property owned by the parties hereto;
c. directing the Defendant to pay alimony to Plaintiff;
d, directing the Defendant to pay alimony pendente lite Plaintiff's counsel
fees and the cost of this suit; and
e. for such further relief as the Court may deterrnlne equitable and Just.
CONNELLY. REID & SPADE
,...
Date: l\~ 11\'11
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By:
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VERIFICATION
I verify that the statements made In this Pleading are true and correct,
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. Section 4904, relating to unsworn falsification to authorities.
Date: \
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VITAL RlCORDI
COUNTY
Cumberland
DIVORCE
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RECORD OF
OR ANNULMENT
(CHECK ONE) 0
STATE fiLE NlJM8ER
STATE filE DAti
HUSBAND
1 NAME (Fnt) (Midc1Ie) (Lal) 2 DATE
OF
A. Pr or BIRTH
" SlrHt Of R.O CIt)t Boto Of n.p Count)' S,.f." PLACE
428 Hogestown Road, Mechanicsburg, Cumberland, Pennsylvania BI~~H
$. NUMBER a. RACE 7 USUAL OCCUPATION
Of THIS 2 WHITE BLACK OTHER (SPKil'yl
....RRlAG. Ui 0 0 Clerk
WIFE
tA.lontJt) CD.,)
08/20/48
(StM Of FOf~ COWIII)')
Ohio
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~ MAIDEN H......e
10 RiSlDEHCE
101 Easterl
" NUMBER
OfI'THIS 2
,,",""lAG.
tFl(lt)
C nthia
tUI<h1H}
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(LnlJ
II DATE (Month) to.,.}
OF
BIRTt< 03/09/62
,."
Pryor
$trHl Of'R.O. Clt)'. 8<xo. Of J\top Count)'
Dr., Mechanicsburg, Cumberland, Pennsylvania
8. RACE
WHITE
00
S.m 11 PLACE
OF
BIRTH
14. USUAl OCCUPATION
(51.,. Of Fonrgn COWl'''''
Pennsylvania
BlACK
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OTHER (Sp,KiIy)
o
Secretary
" PlACE OF (eo.nty) (Sf,,. Of FOBWJn Count",) " DATE OF {MonUt} W.,} frO'"
THIS Solano California THIS
MARRIAGE MARRIAGe 09/16/88
17"- NUMBER OF 178. NUMSE' OF OEPENOENT II PLAINTIFF " DECREE GRANTED 10
CHILDREN THIS CHjLDRe~ UNDER 18 HUSBAND WlF. HUSBAND WIFE OTHER ISpKify)
w.AAlA(l. 1 1 0 [i] 0 IX] 0
'" NUMBER OF HUSBAND WIFE SPLIT cusmov OTHER (S~)
CHILDREN TO 0 II 0
CUSTOOV OF
22 OATE OF CECREE (UonUl) (Do,} 1-
.. SiGNATURE OF
TRANSCRIBING CLERJ<
DATE REPORT SENT (AIotlt/t)
TO VITAL RECOROS
(o.,.)
{"',r}
21. leGAL GROUNDS FOR
DMlRCeOR AHNULH.HT 3301 of the Divorce Code
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 97-6510
CYNTHIA L. PRYOR,
PLAINTIFF
MICHAEL A. PRYOR,
DEFENDANT
: CIVIL ACTION. LAW
: IN DIVORCE
ACCEPTANCE OF SERVICE
I, Andrew C. Sheely, Esquire, attorney for the above-named Defendant, accept aervice of
the Complaint in Divorte on behalf of my client, Michael A. Pryor.
Date: /2. - 15""- q7
dt:!t~~l~
127 South Market Street
Mechanicsburg, PA 17055
(717) 697.7050
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JAMES, SMITH. DURkIN &; CONNELLY. UP
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YCMI AlII NKIIIIY NOTI"IO TO ~ll.O TO
THI .~O..O 'if'THIN
Y'W...n to DAY, Of' "IWlC. 1411'~ 0llI
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OIlIGIHAL 'ILIO IN 'HII ACTION
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO, 97-6510
CYNTHIA L. PRYOR,
Plaintiff
MICHAEL A. PRYOR,
Defendant
: CIVIL ACTION . LAW
: IN DIVORCE
W AlYER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE
DECREE UNDER 6330lCc) OF TilE DIVORCE CODE
1. I consent to the entry of a final Decree of 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.A. Section 4904, relating to
unswom falsification to authorities.
Date: .:...1- ,;J. /.p -t/9
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O'1II0IMAL. 'IL.IO IH 1141. ACTION
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CYNTHIA L. PRYOR,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-6510
MICHAEL A. PRYOR,
Defendant
: CIVIL ACTION. LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE
DECREE UNDER U30Hc) OF THE DIVORCE CODE
I. I consent to the entry of a final Decree of Divorce without notice.
2. I underntand 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
ProthonOla1j' .
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.A. Section 4904, relating to
unsworn falsification to authorities.
Date:
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CYNTHIA I., PRYOR,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-6510
MICHAEL A. PRYOR,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
MfD WAIVER OF COUNSELING
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 21, 1997, and served on .
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have
elapsed from the date of both the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of Notice of Intention
to request entry of the Decree.
4. I hllve been advised of the availability of marriage counseling, and understand that I
may request that the Court require that my spouse and I participate in counseling. I further
understand that the Court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request. Being so advised, I do not request that the Court require
that my spouse and I participate in counseling prior to a divorce decree being handed down by the
Court.
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.A. Section 4904, relating to
unswom falsification to authorities.
Date: ;< -.9/.r~q
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CYNTHIA L. PRYOR,
Plaintiff
: IN TilE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 97-6510
MICHAEL A, PRYOR,
Defendant
: CIVIL ACTION . LAW
: IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
AND WAIVER OF COUNSELING
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 21,1997, and served on Do?{.; I /11") .
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have
elapsed from the date of both the filing and service of the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of Notice oflntention
to request entry of the Decree.
4. I have been advised of the availability of marriage counseling, and understand that I
may request that the Court require that my spouse and I participate in counseling. I further
understand that the Court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request. Being so advised, I do not request that the Court require
that my spouse and I participate in counseling prior to a divorce decree being handed down by the
Court.
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.A. Section 4904, relating to
unsworn falsification to authorities.
Date: /J1auA I, 1'1f'f
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In the Court or Common Pleas or CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
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CYNTHIA L. PRYOR ) Docker Number 97-6510
Plaintiff )
VI. ) PACSES Case Number 6.8100035/D27,316
MICHABL A. PRYOR )
Def~ndanl ) Other Slire ID Number
Order
AND NOW to wit, this
MARCH 16, 1999
it is hereby Ordered
that:
THE ABOVE CAPTIONED ORDER 0' ALIMONY PENDENTE LITE IS TERMINATED, EPPBCTlVE
MARCH 10, 1999, WITH A BALANCE 0' $80.65 OWBD TO THE PETITIONER. SAID
BALANCE IS TO BE PAID WITHIN 'IVE DAYS UPON RBCEIPT 0' THIS ORDER.
DRO: RJ Shadday
xc I pia lnt if
defendant
J. Cunnelly, Esq.
A. Sheely, Esq.
Edward E. G~ldu
JUDGE
Service Type M
Form OE-QOI
Worker ID U005
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HBUlIBY. I'IlI'II'ISYLVAI'IIA 11033.0630
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~ ~~~tHD t;O"JtlcT COPY Of nee
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IV
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97.6510
CYNTHIA L. PRYOR,
Plaintiff
MICHAEL A. PRYOR,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
."'t'
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the Defendant in the above matter having been
granted a Final Decree in Divorce from the bonds of matrimony on the ~ day of
March
. 1993 hereby elects to retake and hereafter use her maiden name of
CYNTHIA L. BUTTS and gives this written notice avowing her intention in accordance
with the provisions of the Act of May 25. 1939. P. L. 192. as amended.
DATED:
March 17, 1999
./
TO BE KNOWN AS
(I, ,.,f li~ /'
C'VNTI'Il(\ L. ,i!tuttl), , "
Sworn to and subscribed
before me this 17th d~y
of ."Oh, i 1999.
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CYNTHIA L. PRYOR, I IN THE COURT or COMMON PLEAS or
plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
va. I NO. 91 - 6510 CIVIL
I
MICHAEL A. PRYOR, I
Detendant I IN DIVORCE
ORDER OF COURT
AND NOW, this ~ day ot ~.)~t..4
1999, the economic claims rais~d in the proceedings having been
resolved in accordance with a property settlement agreement
dated March 1, 1999, the appointment ot the Master is vacated
and counsel can tile a praocipe transmitting the record to the
Court requesting a tinal decree in divorce.
BY THE COURT,
(/ di fer
E
fer,
.J.
cc:
J~n J. Connelly, Jr.
Attorney for Plaintiff
Andrew C. sheely
Attorney tor Defendant
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fROPERTV SETTLEMENT AGREEMENT
TH1S AGREEMENT, made this rl-- day of /VI <<t't, ,1999, by and
between MiCHAEL A. PRYOR, hereinafter called "Husband", and CYNTHIA L. PRYOR,
hereinafter called "Wife".
WITNESSETH:
WHEREAS, Husband and Wife werc legally married on September 16. 1988;
WHEREAS, one child WllS bom of this marriage, Mary 1. pryor, bom September 12,1988;
WHEREAS, differences have arisen between Husband and Wife in consequence of which
they desire to live separate and apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their rights and obligations.
NOW THEREFORE, in consideration of the premises and covenants contained herein, it is
agreed by and between the parties hereto that:
1. SEPARATION.
11 shall be lawful for each party at all times hereafter to live separate and apart from each
other at such place lIS he or she from time to time shall choose or deem fit The foregoing provision
shall not be taken lIS an admission on the part of either partY of the lawfulness or unlawfulness of
the causes leading to their living apart.
1. INTERFERENCES.
Each party shall be free from interference, authority and control by the other, as fully as if he
or she were single and unmarried, except lIS may be necessary to carry out the provisions of this
Agreement. Neither party shall molest or attempt to endeavor to molest the other. or in any way
haraSS or malign the other, nor in any other way interfere with thc peaceful existence, separate and
apart from the other. Each of the parties hereto completely understands and agrees that neither shall
do or say anything to thc child of the parties at any time which might in any way influcnce the child
adversely against the other party.
.
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3. DMSION OF REAL PROPERTY,
The parties were owners owners of real estate located at 428 Hogestown Road,
Mechanicsburg, Cumberland County, PeMsylvania. The parties have sold the marital residence and
have equally divided the proceeds between them. Each of the parties, since their date of separation,
have acquired interest in real eStatc. Each party waivcs any claim thcy may have in any real estate
interest acquired by the other subsequent to their separation.
4. DIVISION OF PER..'iON!.L PROPERTY.
The parties have divided between them to their mutual satisfaction, personal effects,
household goods and fumishings and all other articles of personal property which have heretofore
been used in common by them, and neither party will make any claim to any such items which are
now in the possession or under the control of the other. Should it become necessary, each party
agrees to sign any title or documents necessary to give effect to this paragraph, upon request.
5, CUSTODY AND VISITATION.
'l11e parties have entered into an Ordcr of Court for custody of their minor child,
Mary 1. Pryor, bom September 12, 1988. The said Order is entered to Docket No. 97-6510 in the
Court of Common Pleas, Cumberland County, Pennsylvania. Any changes in the existing custodial
arrangement shall be pursuant to that Order.
6. SUPPORTI ALIMONY PENDENTE LITE.
There is presently a Support Ordcr in the Court of Common Pleas, Cumberland County,
Permsylvania, Docket No. 01037 S I 997/P ACSES Case No. 246100007 providing for the
support/alimony pendente lite of the Wife and the minor child of the parties. Wife agrees,
immediately upon the granting of a Decrce in Divorce, that she shall terminate, with prejudice, and
all claims for alimony pendente lite and/or spousal support presently pending in the Cumberland
County Domestic Relations Office. Any modifications as to child support shall be controlled by the
above-referenced action.
Ii
2
7. TAX ON PROPERTY DIVISION.
Husband hen:by agrees \0 pay all income taxes assessed against him, if any, as a result of
the division of the property of the parties hereunder. Wife hereby agrees to pay all income taxes
assessed against her, if any, as a result of the division of the property of the parties hereunder.
8. MARITAL DEBTS.
Thc parties acknowlcdge that there is no continuing marital debt. Each ofthc parties shall
be responsible for debts in their indi\'idual namcs pursuant to Paragraphs 13 and 14 of this
Agrccment.
All further debts incurred by the parties shall be their individual responsibility.
9. PENSIONS.
Each party shall rctain as their sole and separate property, any and all retirement accounts
and military benefits in their names individually. Specifically, Wifc waives any and all claims that
she may have against Husband's 401(k) plan with Watkins Motor Lincs, Inc. Further, Wife agrees
to waive any and all claims against Husband's military retirement benefits and disability benefits.
Husband agrces to waive any and all claims that he my have against Wife's Aid Association for
Lutheran's (AAL)IRAslAnnuitics.
10. BREACH.
If either party brcaches any provision of this Agreemcnt, the other party shall have the right,
at his or her election, to sue for damages for such breach. The party breaching this contract shall be
responsible for the payment of legal fees and costs incurred by the other in enforcing his or her
rights under this Agreement, or seeking such other remedy or relief as may be available to him or
her.
11. FULL DISCLOSURE.
Husband and Wife each represent and warrant to the other that he or she has made a full and
complete disclosure to the other of all assets of any nature whatsoever in which such party of every
type whatsoever and all other facts relating to the subject maner of this Agreement.
12. ADDITIONAL INSTRUMENT.
Each of the parties shall on .!emand execute and deliver to thc other any deeds, bills of sale,
"
assignment, consents to change of beneficiary on insurance policies, tax returns and other
documents and do or Cllused to be done any other act or thing that may be nece..Ary or desirable to
the provisions and purposes of this Agreement. If either party fails on demand to comply with this
provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonable
incurred as a result of such failure.
13. WIFE'S DEnTS.
Wife represents and warrants to Ilusband that since the parties' separation she has not and in
the future she will not contract or incur any debt or liability for which Husband or his estate might
be responsible and shall indemnify and save Husband harmless from any and all claims or demands
made against him by reason of debts or obligations incurred by her.
14, HUSBAND'S DEBTS.
Husband represents and warrants to Wife that since the parties' separation he has not and in
the future he will not contract or incur any debt or liability for which Wife or her estate might be
responsible and shall indemnify and save Wife harmless from any and all claims or demands made
against her by reason of debts or obligations incurred by him.
15. WAIVERS OF CLAIMS AGAINST ESTATES.
Except as herein otherwise provided, each party may dispose of his or her property in any
way, and each party hereby waives and relinquishes any and all rights he or she may now have or
hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the
estate of the other as a result of the marital relationship, including without limitation, dower, curtsy,
statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of
the other, and right to act as administrator or executor of the other's estate, ..,d each will, to the
request of the other, execute, acknowledl\c, and deliver any and all instruments which may be
necessary or advisable to carry into effect this mutual waiver and relinquishment of all such
interests, rights and claims.
16. REPRESENTATION.
It is recognized by the parties hereto that Michael A. Pryor is represented by Andrew
Andrew C. Sheely, Esquire, and Cynthia L. Pryor is represented by John J. Connelly, Jr., Esquire. It
4
is fully understood and agreed that by the signing of this Agreement, each party undel'Stands the
legal impact of this Agreement and further acknowledges that the Agreement is fair and reasonable
and each party intends to be legally bound by the terms hereof.
17. VOLUNTARY EXECUTION.
The provisions of this Agreement are fully undcrstood by both parties and each party
acknowledges that this Agrccment is fair and cquitable, Ihal it is being cntcrcd inlo voluntarily and
that it is notlhc result of any duress or unduc inl1ucncc.
18. ENTIRE AGREEMENT.
This Agreement ccntains the entire undcl1itanding of the parties and there are no
representations, warrantics, covenants or undertakings other than those expressly set forth herein.
19. PRIOR AGREEMENT.
It is understood and agreed that any and all property settlement agreements which mayor
have been executed prior to the date and time of this Agreement are null and void and of no ~ffect.
20. MODIFICATION AND WAIVER.
Any modification or waiver of any provision of this Agreement shall be effective only if
made in writing and executed with the same formality as this Agreement. The failure of either party
to insist upon strict performance of any of thc provisions of this Agreement shall not be construed as
a waiver of any subsequent default of the same or similar nature.
21. GOVERNING LAW.
This Agreement shall be governed by and shall be construed in accordance with the laws of
the Commonwealth of Pennsylvania.
22. INDEPENDENT SEPARATE COVENANTS.
It is specific&lly understood and agrecd by and between the parties hereto that each
paragraph hereof shall be deemed to be a scparate and independent covenant and agreement.
23. VOID CLAUSES.
If any tcrm, condition, clause, or provision of this Agreement shall be determined or
declared to be void or invalid in law or othcrwise, then only that term, condition, clause or provision
shall be stricKen from this Agreement and in all other respects this Agreement shall be valid and
continue in full force, elTcct and operation.
.,
14. j1:NTRY AS PART OF DECREE.
It is the intention of the parties that this Agreement shall survive any action for divorce
which may be instituted or prosecuted by either party and no order, judgement or decree of divorce,
temporary, final or permanent, shall affect or modify the financial terms of this Agreement. TIlls
Agreement shall be made a part of, but shall not merge with, any such judgment or decree of final
divorce.
25. llIVORCE ACTION.
The parties shall, at the time of the execution of the Agreement, cxecute documents
necessary to finalize the divorce action including, but not limited to, the withdrawal of any claims
pending under said action, indexed to number 97.6510, in the Court of Common Pleas, Cumberland
County, PelUlSylvania, as well as Affidavits of Consent and Waivers of Counseling and Waivers of
Notice of Intention to Request Entry of a Divorce Decree.
16. DOMESTIC RELATIONS CODE OF THE COMMONWEALTH OF
PENNSYLVANIA.
Except as specifically provided in this Agreement, each party waives any claim they may
have against the other under the Domestic Relations Code of the Commonwealth of Pennsylvania
including, but not limited to, alimony, alimony pendente lite, counsel fees, costs and equitable
distribution of marital property.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have
hereunto set their hands and seals the day and year first above written.
WITNESS:
duNJ C'
Andrew C. Sheely,
4(!l;
Michael A. ryor
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CYNTHIA L PRYOR,
Plaintiff/Respondent
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
MICHAEL A. PRYOR,
DefendanllPetilioner
NO. 97 - 6~1O CIVIL TERJ\l
IN DIVORCE
DRJI 270316
Pae.elll 648100UJ~
ORDER OF COURT
AND NOW, Ihis ~ day of Febnnm'. 1999 a petition has been filed againslyou, CYnthia L.
fn:J!L. Resoondenl, to modify an exisling Alimony Pendellle Lite Order. You arc ordered 10 appear In
person allhe Domestic Relations Section, 13 North Hanover Slreet. Carlisle, PennS)'h'ania, on Mareh 2.
.l222. al 9:0UAM, for a conference IInd to remain nnlil dismissed by Ihe Court. If you fail 10 appear as
provided in Ihis Order, an Order for Modificalion mal' be enlered againsl )"ou.
You arc further ordered 10 bring to Ihe conference:
(I) a true copy of)"our most recent Federal Income Tax Relum, including W.2's as filed
(2) )"our pay slubs for Ihe preceding six (6) monlhs
(3) the Income and Expense Statementallached 10 this order, completed as required by the Rule
1911l.11.
(4) verification of child care expenses
(5) proof of medical coverage which you may hll\'e, or may ha,'e IIvailllble to you
IF you filii 10 IIpJlCllr for the conference or bring the required documents, Ihe Court may Issue a
warrant for your arresl.
BY THE COURT.
Gcorge E. Hoffer, President Judge
\
ee: Petitioner-' ~
Respondent ~J
1. Connelly. Jr., Esq. N"liu.
A. Shcely, Esq. -'/.\41'11
Date of Order: hllruarv I. 1999
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R. J. Sh da)', Conference Officcr
YOU HAVE THE R1GIIT TO A LAWYER. WHO MA Y ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17U13
(717) 249-3166
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In the Court or Common Pleas or CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
CYNTHIA L. PRYOR ) Dockct Number 97-6510
Plalmiff )
vs. ) PACSES Case Number 6481000]5
MICIlABL A. PRYOR )
Defcndant ) Other Slale JD Number :J73/~
PETITION FOR MODIFICATION
OF AN EXISTING SUPPORT ORDER
I. The petition of
MICIlABL ARTHUR PRYOR
respectfully
represents that on APRIL 1, 1998
, an Order of Coun was entered for the
support of
CYNTHIA LYNN PRYOR
A true and correct copy of the order is attached to this petition.
Scrvicc Type M
Form OM-SOl
Worker 10 21504
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PRYOR
V. PRYOR
PACSES Case Number; 649100035
2. Petitioner is entitled to 0 increase <il decrease 0 termination 0 reinstatement
o other of this Order because of the following material and substantial change(s) in
circumstance:
7h@ If Go~
WHEREFORE, Petitioner requests that the Court edify the existing order for support.
Attorney for Petitioner
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. fi 4904 relating to
unsworn falsification to authorities.
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Page 2 of 2
Form OM.~I
Worker ID 21504
Service Type M
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-6510 CIVIL TERM
MICHAEL A. PRYOR,
Plaintiff
CYNTHIA L. PRYOR,
Defendant
CIVIL ACTION. LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this -'3~day of ();[;it&,
, 199B, based upon en
agreement of the parties and Stipulation attached hereto, the following Order is
entered:
The parties shall enjoy shared legal custody of the minor child, Mary J. Pryor,
born September 12, 1988, with primary physical custody in the Defendant/Mother,
Cynthia L. Pryor, subject to the partial custody rights of the Plaintiff/Father, Michael
A. Pryor, as follows:
1. Alternating weekends from 5:00 p.m. Friday until Monday morning when
the child shall be returned to school or, during the summer months, to Mother's
residence at a mutually convenient time before Mother leaves for work. In the event
Father works early Monday morning, the child shall be returned to the Mother on
Sunday evening at 8:30 p.m. The said weekend schedule has commenced on Friday,
August 21, 1998.
2. a. During the school year, each Wednesday and Thursday evening from
after school until 8:30 p.m. In the event Father is not working on Thursday then
t
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Father shall have custody from Wednesday after school until Thursday at 8:30 p.m.
In the event Father Is Itot working on a Friday, the Father shall heve custody on
Wednesday after school until 8:30 p.m. on Wednesday evening and from Thursday
after school through the commencement of school on Friday. Father shall have
M'
custody on either Wednesday or Thursday evening, not both evenings.
2.
b. During the Summer months when school is not in session, each
!')
Wednesday and Thursday evening from 3:30 p.m. until 9:30 p.m. In the event Father
is not working on Thursday, then Father shall have custody from Wednesday at 3:30
p.m. until Thursday evening at 9:30 p.m. In the event Father is not working on a
Friday, then father shall have custody on Wednesday at 3:30 p.m. until 9:30 p.m. on
Wednesday evening, and from Thursday at 3:30 p.m. through 9:00 a.m. on Friday.
Father shall have custody on either Wednesday or Thursday evening, not both
evenings.
3. The parties shall alternate till! following holidays: Labor Day, Easter,
Memorial Day and July Fourth. Father shall have the Labor Day holiday In 1998,
Mother shall have Easter in 1999, Father shall have Memorial Day in 1999 and Mother
shall have July Fourth in 1999. The schedule will then rotate in exactly the opposite
fashion beginning with the Labor Day 1999 holiday.
4. The Thanksgiving holiday shall be alterneted between the parents. The
Thanksgiving holiday shall begin after school on Wednesday and end on Fridey
evening at 6:00 p.m. In the event either party's weekend begins on that Friday, that
parent shall retain the child until Monday morning when the child returns to school.
The Thanksgiving holiday schedule shall begin with Father in 1998.
5. The Christmas school holiday shall be divided equally between the
parents. The parties shall divide the Christmas holiday as follows:
The parent who has Christmas Eve and Christmas morning shall retain the child
from the day school ends until 12:00 Noon Christmas Day. The other parent shall
have the child from 12:00 Noon Christmas Day for a period that equals one-half (1/2)
of the school holiday when the child shall be returned to the other parent for the
remainder of the school holiday. The first half of Christmas in 1998 shall be the
Mother's holiday.
6. Mother's Day with Mother and Father's Day with Father regardless of the
weekend schedule from 6:00 p.m. on Saturday evening until Monday morning
following the holiday.
7. Each of the parties shall be entitled to two (2) non-consecutive weeks of
summer vacation with a minimum of thirty (30) days written notice to the other party.
The party first selecting the vacation shall be entitled to preference. A vacation shall
not be elected over the other party's scheduled holidays.
8. All pick-ups and drop-offs shall occur at the residences of Father and
Mother unless specific arrangements are made to the contrary and are agreed to by
,
.
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the parties.
9. Father and Mother shall discuss and communicate with one another prior
to enrolling the child in any extra-curricular activities so as to mini mile interference
with the custody schedules as set forth above. Father and Mother shall also provide
each other with all schedules of activities relevant to any extra-curricular activities in
10. Father and Mother shall discuss and communicate with one another prior
which the child is involved.
to enrolling the child in any church related activities, other than normal worship
services during Father and Mother's respective weekends.
11. Any other times mutually agreed upon by the parties.
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MICHAEL A. PRYOR.
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 97-6510 CIVIL TERM
v.
CYNTHIA L. PRYOR.
Defendant
CIVIL ACTION. LAW
IN CUSTODY
CUSTODY STIPULATION
~
WHEREAS. Michael A. Pryor is the natural father of Mary J. Pryor. born
September 12. 1988; and
WHEREAS. Cynthia L. Pryor is the natural mother of Mary J. Pryor; and
WHEREAS. Michael A. Pryor is represented by Andrew C. Sheely, Esquire. and
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Cynthia L. Pryor is represented by John J. Connelly, Jr.. Esquire; and
WHEREAS. it is the desire of the parties to enter into the following Custody
Stipulation.
NOW THEREFORE. the parties mutually agree as follows:
The parties shall enjoy shared legal custody of the minor child. Mary J. Pryor.
born September 12. 1988, wi~h primary physical custody in the Defendant/Mother,
Cynthia L. Pryor, subject to the partial custody rights of the Plaintiff/Father. Michael
A. Pryor. as follows:
1. Alternating weekends from 5:00 p.m. Friday until Monday morning when
the child shall be returned to school or, during the summer months, to Mother's
residence at a mutually convenient time before Mother leaves for work. In the event
Father works early Monday morning, the child shall be returned to the Mother on
Sunday evening at 8:30 p.m. The said weekend schedule has commenced on Friday,
August 21, 1998.
2.
a. During the school year, each Wednesday and Thursdey evening from
~
,
after school until 8:30 p.m. In the event Father is not working on Thursday then
2. b. During the Summer months when school is not in stlssion, each
Father shall have custody from Wednesday after school until Thursday at 8:30 p.m.
In the event Father is not working on a Friday, the Father shall have custody on
Wednesday after school until 8:30 p.m. on Wednesday evening and from Thursday
after school through the commencement of school on Friday. Father shall have
custody on either Wednesday or Thursday evening, not both evenings.
Wednesday and Thursday evening from 3:30 p.m. until 9:30 p.m. In the event Father
is not working on Thursday, then Father shall have custody from Wednesday at 3:30
p.m. until Thursday evening at 9:30 p.m. In the event Father is not working on a
Friday, then father shall have custody on Wednesday at 3:30 p.m. until 9:30 p.m. on
Wednesday evening, and from Thursday at 3:30 p.m. through 9:00 a.m. on Friday.
Father shall have custody on either Wednesday or Thursday evening, not both
evenings.
3. The parties shall alternate the following holidays: Labor Day, Easter,
Memorial Day and July Fourth. Father shall have the Labor Day holiday in 1998,
Mother shall have Easter in 1999, Father shall have Memorial Day in 1999 and Mother
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shall have July Fourth in 1999. The schedule will then rotate in exactly tha oppl.~ite
fashion beginning with the Labor Day 1999 holiday.
4. The Thanksgiving holiday shall be alternated between the parents. The
Thanksgiving holiday shall begin after school on Wednesday and end on Friday
evening at 6:00 p.m. In the event either party's weekend begins on that Friday, that
~
parent shall retain the child until Monday morning when the child returns to school.
5. The Christmas school holiday shall be divided equally between the
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The Thanksgiving holiday schedule shall be~in with Father in 1998.
parents. The parties shall divide the Christmas holiday as follows:
The parent who has Christmas Eve and Christmas morning shall retain the child
\
from the day school ends until 12:00 Noon Christmas Day. The other parant shall
have the child from 12:00 Noon Christmas Day for a period that equals one-half (1/2)
of the school holiday when the child shall be returned to the other parent for the
remainder of the school holiday. The first half of Christmas in 1998 shall be tha
Mother's holiday.
6. Mother's Day with Mother and Father's Day with Father regardless of the
weekend schedule from 6:00 p.rTI. on Saturday evening until Monday morning
following the holiday.
7. Each of the parties shall be entitled to two (2) non-consecutive weeks of
summer vacation with a minimum of thirty (30) days written notice to the other party.
The party first selecting the vacation shall be entitled to preference. A vacation shall
ARdr.v C. Sh..ly, I.quire
IJ1 S. Market Street
P,O, lox 9S
. Mechanlc.burq, PA 110SS
PA ID NO. 6H69
717_697_7050 (phon.,
717_697_7065 (r..)
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.
MICHAEL A. PRYOR,
plaintiff
I IN THE COURT OF COMMON PLEAS OF
I Cl~ERLAND COUNTY, PENNSYLVANIA
I
I CIVIL ACTION - LAW
I
I 9' -I. ~ II) CIVIL TERM
I
vs.
CYNTHIA L. PRYOR,
Respondent
IN CUSTODY
ORDER 0.. COURT
AND NOW, -1 ,-\L..\\q~ ,1998, upon consideration of
the attached petltion, it is hereby directed that the parties and
their respective counsel appear before r-nv...A\ -S I ,'1....1"""\("0'-..1 I~'
, the conCIIIat r, at -,
on the day 0 ' 1998, at
rl '. r,D o'clock .&.m., or a re Hearing Custody Conference.
At such conference,-xn effort will be made to resolve the issues
in dispute; or if t~is cannot be accomplished, to define and
narrow the issues to be heard by the court, and to enter into a
temporary order. All children age five or older may also be
present at the conference. Failure to appear at the conference
may provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By:d~~\.~ J\.~~~
Custody Conc 1 ator
("\t::):')
The Court of Common Pleas of Cumberland county is required by law
to comply with the Americans with Disabilities Act of 1990. For
information about accessible facilities and reasonable
accommodations available to disabled individuals having business
before the court, please contact our office. All arrangements
must be made at least 72 hours priur to any hearing or business
before the court. You must attend the scheduled conference or
hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT OHCE.
I" YOU DO NOT HAVt A LAWYER OR CANNOT A....ORD OHE, GO TO OR
TZL~PHONZ THE O....ICE SET "ORTH BELOW TO "IND OUT WHERI YOU
CAN GET LEGAL HELP.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, pennsylvania 17013
(717) 249-6200
.
MICHAEL A. PRYOR, IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I CIVIL ACTION - LAW
.
.
CYNTHIA L. PRYOR, I 9 I - blS"IO CIVIL TERM
I
Respondent I IN CUSTODY
COMPLAINT rOR CUSTODY AND ORDER or COURT
TO THE HONORABLE, THE JUDGES OF THE SAID COURT I
1. Plaintiff is Michael A. Pryor, an adult individual who
currently resides at 428 Hogestown Road, Mechanicsburg, Cumberland
County, pennsylvania.
2. Defendant is Cynthia L. Pryor, an adult individual who
currently resides at 101 Easterly Drive, Mechanicsburg, Cumberland
County, pennsylvania.
3. Plaintiff seeks a custody order involving the minor
child, MARY J. PRYOR, D.O.B. 9/12/88.
4. The parties are the natural parents of the minor child.
The parties currently maintain separate residences.
5. During the past five (5) years, the child has resided at
428 Hogestown, Mechanicsburg, Pennsylvania, with both parties, and
exclusively with Defendant at 101 Easterly Drive, Mechanicsburg,
Pennsylvania, since November 13, 1997.
6. The natural father of the child is Plaintiff who currently
resides alone at the former marital residence.
7. The natural mother of the child is Defendant. It is
unknown whether Defendant is officially residing with anyone at
the 101 Easterly Drive, Mechanicsburg, Pennsylvania location.
8. No prior custody order or agreement exists between the
parties involving the child and plaintiff has no knowledge of any
other litigation concerning the custody of the child in this or
another court and Plaintiff has no information of a custody
proceeding concerning the child pending in a court of this
Commonwealth.
9. Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
10. Since November 13, 1997, Plaintiff's attempts to have
reasonable custody contact with the child have resulted in
substantial resistance by Defendant, resulting in sporadic
contacts between Father and the child at Defendant's personal
convenience and luxury.
11. A regular and routine custody contact period between
Father and child is warranted and in the best interest of the
child.
12. The best interests and permanent welfare of the child,
Mary J. pryor, will be served by ordering that both parties share
legal and physical custody of the child and directing that a
custody order be entered directing that Plaintiff shall have
shared legal and physical custody of the child, alternating
holidays with the child and an extended summer vacation period for
the following reasons:
(A) plaintiff is a fit parent who can take car3 of his child
and who can provide her with a supportive, safe and healthy
2
ellvironment in the former marital residence where the child lived
for eight (8) years prior to separation;
(B) Plaintiff's work schedule is ideal for a shared physical
custody arrangement in that he has substantial number of days off
per week where he is not required to work and where he could
engage in meaningful and appropriate activities with the child,
all to the child's benefit;
(C) Defendant's conduct and behavior is not in the best
interest of the child in that:
(i) Defendant has refused to allow plaintiff regular and
routille contact with the child; and
(ii) Defendant has refused to communicate regularly with
Plaintiff concerning the child and Defendant continues to act in an
irresponsible manner without consideration of the interests of the
minor child; and
(iii) Defendant has not participated in any transportation
provisions on a regular basis for the minor child forcing plaintiff
to incur the majority of transportation for the custody contacts,
all at Defendant's luxury; 3nd
(iv) Defendant has not afforded Plaintiff with the
opportunity to spend substantial time with the child and has
refused to cooperate with Plaintiff depriving Plaintiff of
meaningful custody contacts between Father and daughter.
13. Plaintiff is capable and willing to insure that the child
attends and is prepared for daily school activities while she resides
with him at the former marital residence and no legitimate reason exists
to deny Plaintiff a substantial and meaningful custody contact period
with his daughter.
14. Each parent whose parental rights to the child have not been
terminated and the person who has physical custody of the child have
been named as parties to this action,
3
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WHEREFORE, Michael A. pryor, plaintiff, respectfully requests that
your Honorable Court enter an Order of Court which grants him legal and
physical custody of the minor child, with alternating holidays and an
extensive summer custody contact period and that Defendant be directed
to share transportation responsibilities with the child.
.'JJ
Datel January 1, 1998
Respectfully submitted,
An!::~e~~y~
Attorney for plaintiff
PA ID NO. 62469
P.O. Box 95
127 S. Market Street
Mechanicsburg, PA 17055
717-697-7050
717-697-7065 (FAX)
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I verify that the statements made in this Complaint for Custody are true
and correct. I understand that false statements herein are made subject
to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: January9, 1998
~
iiichael A. pry r
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I IN THB COURT OJ' COMMON PLBAS
I CUMBBRLAND COUN'l'Y, PENNSYLVANIA
I
I NO. 97 - 6510 CIVIL
I
I CIVIL ACTION - LAW
I IN CUSTODY
MICHABL A. PRYOR,
Plaintiff
CYNTHIA L. PRYOR,
Defendant
PRAECIPE FUR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of John J. Connelly, Jr., Esquire
on behalf of the Defendant, Cynthia L. Pryor, in the above-
captioned action.
CONNELLY,
Date: I-/q-Cf-r
By:
squire
"
:)
Andrew C. Sh..ly, ..quire
121 S. Market Stre.t
P.o. Box 95
Hechanic.burq, PA 110!!
PA 10 NO. 6H69
711-691-7050 (Phone)
711.691-1065 (r.X)
MICHAEL A. PRYOR, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
VS. I CIVIL ACTION - LAW
I
CYNTHIA L. PRYOR, I 97 - 6510 CIVIL TERM
I
Respondent I IN CUSTODY
ACCEPTANCE OF SERVICE
I, John J. Connelly, Esquire, hereby accept service of the complaint/petition for
custody on behalf of Cynthia L. Pryor, Respondent, and further certify that I am
authorized to do so in accordance with PA. R.C.P No. 402 (b).
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MICHAEL A. PRlrOR, IN THE COURT OF COolMCN PLEAS OF
Plaintiff . CUMBERLAND axJNT'i, PENNSlrLVANIA
.
I
VB. I NO. 97-6510 CIVIL TERM
I CIVIL ACTION - LAW
CYNl'HIA L. PRYOR, I
Reapondent . IN CUS'roOlr
.
(JUJI!R CR oom
Nm tDf, this ~..y,.. day of ~~6
consideratioo of the attached CUstody Conc at on Report,
and directed as follows:
, 1998, upon
it is ordered
1. The Father, Michael A. pryor, and the Mother, Cynthia L. Pryor,
shall have shared legal custody of Mary J. Pryor, born Septerrber 12, 1988.
Each parent shall have an equal right, to be exercised jointly with the
other parent, to make all major non-emergency decisions affecting the
Child's general woll-being including, but not limited to, all decisions
regarding her health, education, and religion.
2. The Mother shall have primary physical custody of the Child.
3. The Father shall have partial physical custody of the Child on
alternating weekends, beginning February 13, 1998, fran after school lUltil
Sunday at 9:00 p.m. In addition, the Father shall have custody of the
Child on weekday evenings Monday through Thursday, when the Father works
fran after school lUltil 5:15 p.m., and on weekday evenings, Monday through
Thursday, when the Father doesn't work from after school until 9:00 p.m.
4. 01 Easter sunday in 1998, which falls on the Father's regular
weekend period of cust:ody, the Father shall return the Child to the
Mother's custody at 1:00 p.m.
5. The parties and counsel shall attend a second Conciliation
Conference at the office of the Conciliator, Dawn S. SlUlday, Esquire, on
May 5, 1998 at 9:00 a.m.
6. This order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties may modify the provisions of
this order by IllIJtual consent. In the absence of mutual consent, the terms
of this order shall control.
J.
CCI Andrew C. Sheely, Esquire - Counsel for Father
John J. COnnelly, Jr., Esquire - Counsel for Mother
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MICHAEL A. PRYOR, I IN THE COURT OF CDlMOO PLEAS OF
Plaintiff I CUMBERLAND CCXJNTY, PENNSYLVANIA
.
.
VB. . NO. 97-6510 CIVIL TERM
.
I
CYm'HIA L. PRYOR, . CIVIL ACTION - LAW
.
Respondent . CUSTODY
.
am'CIll!' CXH:ILIATICIi SlMIt.RY REPCRl'
IN ACXX:IlDANCB wrm <1IlBmLAND CXXNl'Y RULE CP CZVIL PAC- "uN
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
IWlB
DATE CP BIRTH
ClIlRF2m.Y IN CU91'<Dr CP
Mary J. Pryor
September 12, 1988
Mother
2. A Conciliation Conference was held in this matter on February 12,
1998, with the following individuals in attendance: The Father, Michael A.
Pryor, with his counsel, Andrew C. Sheely, Esquire, and the Mother, Cynthia
L. Pryor, with her counsel, John J. Connelly, Jr., Esquire.
3. The parties agreed
12j,,,,,,...,., r:! 19U'"
Date (J .
to entry of an Order in the form as attached.
rQ..~.a-'
Dalm S. Sunday, Esquire 1
CUstody Conciliator
MICHAEL A. PR~, . IN THE CXXJRT OF ~ PLFAS OF
.
Plaintiff . CUMBERLAND COONTY, PENNSYLVANIA
.
VS. . NO. 97-6510 CIVIL TERM
.
I
CYNl'HIA L. PRYOO, I CIVIL ACTION - LAW
Defendant I CUS'roDY
PRICE JtI)G8: Geol:ge B. Dotfer
<lUlI!R CI CDRl'
AND tUf, this I' ~ day of ftIl ~
consideration ot the attached CUstody Concil at on
and directed as follows:
, 1998, upon
Report, it is ordered
1. A Hearing is scheduled in Court Roan No. S , of the
Cunberland County Court House on the JA;. AlJ day of ,.3r.../t/
1998, at '/:01 o'clock, ~.m., at whlCFi time teSElmony will be taken
in this case. For purposes of this Hearing, the Father shall be deemed to
be the moving party and shall proceed initially with testimony. Counsel
for the parties shall file with the Court and opposing counsel a Memorandum
setting forth each party's position on custody, a list of witnesses who
will be called to testify at the Hearing, and a summary of the anticipated
testimony of each witness. These Memoranda shall be filed at least ten
(10) days prior to the scheduled Hearing date.
2. The parties shall submit themselves, their Child, Mary J. Pryor,
and any other family members deemed necessary, to a psychological/custody
evaluation to be performed by Arnold Shienvold, PhD. The purpose of the
evaluation shall be to obtain an independent opinion and recomnendation
with regard to ongoing custody arrangements as well as special concerns,
such as the Father's request for extended vacation custody. The parties
shall sign all necessary releases and authorizations for the evaluator to
obtain information pertaining to the parties and the Child. The cost of
the evaluation shall be shared equally by the parties.
3. Pending further Order of Court or agreement of the parties, the
prior Order of this Oourt dated February 20, 1998 shall continue in effect
with the following modifications or additions:
A. The Father's periods of partial custody shall end at 8:30 p.m.
when the Child has school the following day and at 9:30 p.m.
when the Child does not have school the following day.
8. In 1998, the Mother shall have custody of the Child on
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Memorial Day and the Father shall have custody of the Child on
July 4th.
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eel Andrew C. Sheely, Esquire - Counsel for Father - {'~~ sf~/9.
John J. connelly, Jr., Esquire - Counsel for Mother -(1-' ~ P.
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Plaintiff
: IN THE OOURT OF cn1MCtl PLEAS OF
CUMBERLAND COONTY, PENNSYLVANIA
vs.
: NO. 97-6510 CIVIL TERM
:
CYNTHIA L. PRYOR,
Defendant
: CIVIL ACTION - LAW
: CUSTODY
PRIOR JUDGE: Edward E. Guido
amalY <XH:ILIATICfi SlJIIIIARY RJllICR1'
IN AO:X:IlIlAN:B wrm CIJm/!IU.AND a1If1'lf' RULE OI! CIVIL PRO... ~
1915.3-8, the undersigned Custody Conciliator subnits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
IWIB
DATE OI! BIRl'Il
ClIlRmrLY IN CIlSTCDY Of!'
Mary J. Pryor
Septellt>er 12, 1988
Mother
2. A second Conciliation Conference was held on May 5, 1998, with the
tollowilKj indivicfuals in attendance: The Father, Michael A. Pryor, with
his coUDsel, Andrew C. Sheely, Esquire, and the Mother, Cynthia L. Pryor,
with her counsel, John J. Connelly, Jr., Esquire.
3. The parties agreed at the Conference to obtain a custody
evaluation from Arnold Shienvold to address serious allegations raised by
the parties in connection with the best interests of the Child and to
assist the partios in attempting to reach an agreement on ongoing custody
arrangements. Counsel for the parties requested that a Hearing be
scheduled to provide a deadline for the evaluator's report and
recommendation and to avoid further delay in the event the parties are not
able to reach an agreement after the evaluation is carpleted.
4. The Father's position on custody is as follows: The Father
believes the Child has been doing well under the current custody schedule
but feels it would be in the Child's best interest to spend additional time
with the Father. The Father feels that the Mother discourages the
relationship between the Father and the Child. The Father believes that
the Mother's efforts to reduce his contact with the Child are unjustified
and detrimental to the Olild. The Father disagrees with the Mother's
representation that the Child is doing poorly in school and stated that his
contacts with the Child's teachers indicate otherwise. The Father
specifically requested an extended period of custody with the Child for
vacation from July 30, 1998 through August 12, 1998.
5. The Mother's position on custody is as follows: The Mother
believes that the current custody schedule is detrimental to the Child's
well-being in that, according to the Mother, the Child's grades are falling
in school, the Child has nightmares at night, seems tired during the clay
and does not want to spend additional time with the Father. The Mother
alleged that the Father has emotional problems which require that his
contact with the Child be decreased. The Mother strongly objected to the
Child going on vacation with the Father for an extended period of time as
requested.
I
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6. Based upon the representations made at the COnference by the
parties and counsel, the Conciliator recoomencla an Order in the form as
attached, appointing Arnold Shienvold to conduct a CUatody Evaluation,
scheduling a Hearing, and making minor changes to the existing order as
agreed by the parties. It is anticipated by the Conciliator that the
evaluation will assist the parties in resolving this matter and that the
Hearing will not ultimately be necesDary.
ff/a,-, "), J C) 'Jk
Dete fJ #
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iiiiwn S. Sunday, Esqu re
CUstody Conciliator
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DR 27.3 16
Pacses# 648100035
CYNTHIA L. PRYOR
PLAINTIFF/PETITIONER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
VS
CIVIL ACTION - LAW
MKHAEL A PRYOR..
DEFENDANT/RESPONDENT:
NO. 97- 6510 CIVIL TERM
ORDER OF COllRT
AND NOW, this ~ day of-&lliL, 1997, based upon the Court's determination that
Petitioner's monthly net income is $ 1.345.00 per monlh and Respondent's monthly net income is
$ 3.450,00 pcr month, it is hereby Ordered that the Respondent pay to the Domestic Relations
Section, Court of Common Picas, $ 486.00 a month payable $ 223.65 bi-weekly as alimony pendente
lite, effective 4/01/98. This order is based upon the child support ord(;r 01'2/11198 and upon
allreementofthe parties. Arrears set at $ 486.00 as of 4/01/98, shall be payable at $ N/A . First
payment due on or before N/ A , and each month thereafter.
Failure to make each payment on time and infltll will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.~ 3703. Further, if the Court finds,
after hearing, that the Respondent has willflllly failed to comply with this Order, it may declare the
Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not
limited 10, commitment of the Respondenl to prison for a period not to exceed six months.
Payments must be made by cash. check or money order. Cash payments musl be made in
person. All checks and money orders must be made payable to Domestic Relations Section and
delivered or mailed to Domestic Relations Section, 13 North Hanover Street, P.O. Box 320, Carlisle,
Pennsylvania, 17013. Each payment must bear your Domestic Relalions number (Pacses#
648100OJ5 ) in order 10 be processed.
Respondent is responsible for service fees of N/ A 10 be paid within N/ A as determined by
the Domestic Relations Section.
,
This Order shall become linalten days aller the mailing oflhe notice of the entry of the Order
to the parties unless either party tiles a written demand with the Prothonotary lilr a hearing de novo
before the Court.
Copies delivered to parties on . 'olfl ~ -t~ /l~h . 4. (., . 'l8
Consented:
PlaintilliPetitioner PlaintilllPetitioner's Attorney
Defendant/Respondent Defendant/Respondent's Attorney
DRO: R.I. Shadday .
cc: petitioner and respondenl\
cc: John 1. Connelly, Jr., Esq. ~ ("r\<.Wl..J
cc: Andrew C. Sheely, Esq. . ")/'kt':.u.
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Edward E. Guido,
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MICHAEL A, PRYOR I
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IN THE COURT OF COI~ON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-6510 CIVIL TERM
ORDER OF COUR'l'
AND NOW, this 24th day of JULY, 1999, at the request of
counsel, the hearing scheduled for July 22, 1998, is continued
until Monday, Au~ust 24, 1998, at 9130 a.m. in Courtroom '5.
J.
John Connelly, Jr., E"quire
For the Plaintiff
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Andrew C. Sheely, Esquire
For the Defendant
IBId
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F:lFD-DtF1CE
Cf THe 1T(..nl('~;OTNW
98 JUL 2 i AIIII: L 6
CUMoER';;,,1) Ct.iUNTY
PEf'.<NSYLV.tN!A
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CYNTHIA L. PRYOR 1
1
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V. 1
1
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MICHAEL A. PRYOR I
.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-6510 CIVIL TERM
ORDER OF COURT
AND NOW, thi. 25th day of SEPTEMBER, 1998, a hearing i.
8chedu1ed for Monday, October 12, 1998, at 12100 noon in
Courtroom' 5.
Edward E. Guido, J.
John Connelly, Jr., E8quire
For the Plaintiff
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Andrew C. Sheely, Esquire
For the Defendant
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ANI>RI:W C. SIIImLY
A"ITORNEl' AT fA W
T,I,pl"",,, 1"117) b'J7.7ll50
127 'slIulb M"rl,l1l ~1m11
P.\,,'11J1I195
MllCh~llk.l)ur~, PCllll.yl\l4uia 17055
1'..,1717) tl'l7.'I0b5
September 21, 1998
The Honorable Edward E. Guido
One Courthouse Square
Carlisle, PA 17013
RE: fmll
97-6510 Custody
Dear Judge Guido:
A hearing was schoduled for late August on the above-referenced matter,
However, Attorney Connelly advised your office that an agreement had been reached
and the matter was taken off your schedule.
To date, no agreement, stipulation or Order has been agreed upon by the
parties, As such, I am requesting that the matter be placed back on your schedule so
as to either conduct a hearing or reach an agreement on record as to custody.
I am copying this letter to Attorney Connelly so that he Is aware of this request.
Very truly you.~'l.. (}A'
j}rtIJt.J C -tJ vw.o
ANDREW C, SHEELY
ACS/cjs
c: Michael A, Pryor
John Connelly, Esquire
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CYNTHIA L PRYOR
PlainlilTlPelitioner
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
MICHAEL A. PRYOR
DcfendllnllRespondenl
NO. 97 . 6~11l CIVIL TERM
IN DIVORCE
DRN 270316
PMCSC!lll 64HllltltlJ!I
ORIlF:R OF COllRT
AND NOW. this JJ!Ih. dIly of.fil1ruiln:.. 199K. upon consideration of the auached Petition for
Alimony Pendente Lite and/or counscl fees. it is hereby direcled that the parties and their respective
counsel appear before R.J. Shadd;lv on Aorill. 1')9K lit 9'OOI\.ln. for n conference. at 13 N. HlInover
SI.. Carli sic. PA l1oD. IIncr which Ihc confcrcnce omcer may recommend thut an Ordcr for Alimony
Pendenlc Lile be cntcred.
YOU are further ordered 10 bring 10 Ihe conference:
(Il a true copy of your mosl recent Federal Income Tux Relurn. including W.2's as filed
(2) yonr puy slubs for the preceding six ((,) monlhs
(3) the Income and Expensc Slulement auached 10 Ihis ordcr. complcted as requircd by Rule
1911I.1111
(4) \'elilieation of child cme cxpenscs
(3) proof of medieal covelllge which yonll1ay havc. or nUll' IUlvc availablc to you
IF you fail 10 appeur for the eonfercncc or bring Ihc required documcnts. the Court may issuc a
wurranl for your IIITCSI.
cc: petitioncr lIud responde~t
cc: John Conuelly. Jr.. Esq. f"u,ll....j
cc: Andrew Sheely. E5ll...- 1IllL.<.. ./,ql'l'll
Dale of Order: FebnlllIV I K. IWK
YOU HAVE TilE RIGIIT TO A LAWYER, WHOE MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. IF YOU DO NOT IIA VE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE TilE OFFICE SET FORTII BELOW TO FIND OUT WIIERE YOU MAY GET
LEGAL HELP.
COURT ADMINISTRATOR
FOURTH FLOOR
CUMBERLAND COUNTY COURT HOUSE
CARLISLE. PENNSYLVANIA 17013
(717) 2~O.(j200
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CYNTHIA L, PRYOR,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO, 97 . 6510
MICHAEL A. PRYOR,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE
AND COUNSEL FEES AND EXPENSES
AND NOWf comes the Plaintifff Cynthia L, Pryorf by her attorney, John J,
Connelly, Jr., Esqulref and petitions this Honorable Court for alimony pendente lite,
counsel feell and expenses relevant to her Complaint In Divorce, and In support
thereof, respectfully represents as follows:
1. By reason of this action, Plaintiff has Incurred considerable expense In
the preparation of her case and the employment of counsel and the payment of costs.
2. The Plaintiff is without sufficient funds to support herself and to meet
the costs and expenses of this litigation.
3. Plaintiff's income is not sufficient to provide for her reasonable needs and
to pay her attorneysf fees and the cost of this litigation and she is unable to
appropriately maintain herself during the pendency of this action.
4. Defendant has adequate earnings to provide for the Plaintiff's support
and to pay her counsel feesf costs and expenses.
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WHEREFORE, Plaintiff prays this Honorable court enter an Order awarding her
alimony pendente lite, counsel fees, costs and expenses.
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Respectfully submitted,
Date: J -I () -9'8
,
By:
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VERIFICATION
I verify that the statements made In this Pleading are true and correct, I
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. Section 4904f relating to unsworn falsification to autho tie' .
Date: ,-1-/0 -.:.; F:
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240.6535
I. Robert IlIck.r, II
Divorce Maste,
Tracl Jo Col".r
Ofllee ManagerlR~porter
w..t Shore
697.0371 Ext. 6535
October 16, 1998
Andrew C. Sheely, Esquire
P.O. Box 95
Mechanicsburg, PA 17055
John J. Connelly, Jr., Esquire
JAMES, SMITH, DURKIN & CONNELLY
P.O. Box 650
Hershey, PA 17033
RE: Cynthia L. Pryor vs. Michael A. Pryor
No, 97 - 6510 civil
In Divorce
Dear Mr. Connelly and Mr. Sheely:
By order of Court of President Judge George E. Hoffer
dated October 7, 1998, the full-time Master has been appointed
in the above referenced divorce proceedings.
A divorce complaint was filed on November 21, 1997,
raising grounds for divorce of irretrievable breakdown of the
marriage and indignities, The complaint also raised the
economic claims of equitable distribution, alimony, alimony
pendente lite, and counsel fees and expenses.
I am going to proceed on the assumption that grounds for
divorce are not an issue; however, if the parties have not been
separated for a period in excess of two years or are not willing
to sign affidavits of consent, please advise and I will
immediately schedule a hearing on the alternative grounds of
indignities as raised in the complaint.
Assuming that grounds for divorce are not an issue, I am
directing each counsel in accordance with P.R.C.P. 1920.33(b) to
file a pre-trial statement on or before Friday, November 6,
1998. Upon receipt of the pre-trial statements, I will
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Mr. Connelly and Mr. Sheely, Attorneys at Law
16 October 1998
Paae 2
immediately schedule a pre-hearing conterence with coun.el to
discuss the issue. and, it necessary, schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions tor tailure to rile the pre-trial statements
are set torth in subdivision Cc) and Cd) or Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COpy SENT DIRECTLY TO OPPOSING
COUNSEL.
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[:1 nil!: COURT OF COM}\ON PLEAS OF
CUMBERLAND COUNTt. PENNSYLVANIA
Cynthia L. Pryor.
PbintiH
vs.
Michael A. Pryor
110.
97-6510
19_
MOTION FOR APPOINTMENT OF HASTER
(Plaintiff) ..llJIMIKX),
following claims:
moves the court to appoint
Cynthia L. Pryor
a master with re.p.ct to the
( ) Divorce
( ) Annulm.nt
(XX) Alimony
(XX) Alimony Pendente
Lite
(xx)
( )
(xX)
(xX)
Distribution of Property
Support
Counsel Fees
Cas ts and Expenses
aod in support of the motion state.:
(l) Discovery is complete as to the claims(s) for which the
appointment of a mast.r is requested.
(2) The defendant (has) ~~~) sppeared 1n the action ~~lii~~ill~)
(by his attomsy. Andrew C. Sheely, Esquire ,Esquire).
(3) The staturory ground(s) for divorce (is) (are)
[rret rievab Ie break d:l\m/ [n dignities.
(4) Delete the inapplicable paragraph(s):
(a) The action i. not contested,
(b) An agreEment has been reached with respect to the
follOWing claims:
(c) The action is contested with respect to the follow1ng
claims: Equitable Distribution, Allmony, Allmony Pendente LHe, Counsel Fee., Costs an.d
(5) The action (involves) (does not involve) complex i.sues of law Expense.
or fact,
(6) The hearing 1. expected to take
(7) Additional information. if any.
(day.).
Date:.3..-J,g-n
J
&c7ib.
Eaqu ire,
AND NOW
i. appoint.d mast.r with
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TWl.HT'V taG CIA'" CW "lWfCI "...~ o.
A OI'4UU JUDOMaNT IIIAY I' INT .:
AOAIH'l' you.
LAw OFFICE
JAMES, SMITH. DURKIN &: CONNELLY, UP
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WI "C..'T CCIIlI"" THAT TH_ WITHIN I.
" '"UI AHD CO..ICT COPT 0' THC
Q.UDIMAL '11.&0 IN THI' ACTION.
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HERSHEY. PENNSYLVANIA I1OJJ.fiI.lO
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CYNTHIA L. PRYOR,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY. PENNSYLVANIA
v.
: NO. 97-6310
MICHAEL A, PRYOR,
Defendant
: CIVIL ACTION. LAW
: IN DIVORCE
PRAECIPE TO WITHDRAW CLAIMS
TO THE PROTHONOTARY:
Please withdraw the claims for Equitable Distribution, Alimony, Alimony Pendente Lite,
Counsel Fees and Expenses in the above-captioned divorce action.
JAMES, SMITH, DURKIN '" CONNELLY LLP
Date: J.. ,JlrtJ9
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