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HomeMy WebLinkAbout03-0688J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE SHANNON KAUTZ, : Defendant NO. ?()3 , l> Y ? CIVIL TERM 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 judgement 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 child. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 prior to any hearing or business before the court. You must attend the scheduled conference or hearing. J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE SHANNON KAUTZ, Defendant NO. ?3 - (P CIVIL TERM COMPLAINT UNDER 23 Pa.C.S. 3301(c) and d OF THE DIVORCE CODE The plaintiff, J. Frank Kautz, by his attorneys, the Family Law Clinic, sets forth the following cause of action: 1. Plaintiff is J. Frank Kautz, who currently resides at 126 South Second Street, Wormleysburg, Cumberland County, Pennsylvania 17043. 2. Defendant is Shannon Kautz, who currently resides at 145 South Second Street, Apartment 2, Highspire, Dauphin County, Pennsylvania 17034. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The plaintiff and defendant were married October 28, 1997 in Cumberland County, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since January 23, 2000. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce dissolving the marriage. Erin L. Benson Certified Legal Intern ROBE RAINS THOMAS M. PLACE LUCY JOHNSTON-WALSH Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa. C. S. §4904, the undersigned verifies that the statements made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. Dated: (<?) • -7 J J. Frank Ka z C- r -r-) ,., , ?H ? \ - ?` w - \'? _? J. FRANK KAUTZ, Plaintiff V. SHANNON KAUTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 03.4 D O CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Sheri£ Kindly allow J. Frank Kautz, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date Z Respectfully submitted, Erin L. Benson Certified Legal Intern 4v' THOA LACE ROB E. RAINS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION-LAW DIVORCE SHANNON KAUTZ, Defendant NO. 03-688 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on your or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated in January 2000 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: 6 LO? PO jrandk?autz , PI ' f r ? ?? i ??jt ;' t '; ?r CI3, t !'? ? C.: ? -_- ?,? ,,? ? t t.D ?J '. J. FRANK KAUTZ, Plaintiff V. SHANNON KAUTZ, : Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 03-688 ACCEPTANCE OF SERVICE CIVIL TERM I accept service of the Divorce Complaint (on behalf of Shannon Kautz and certify that I am authorized to do so). Date: ?-. Z S, 0 3 Robert B. Lieberman, Esq. Attorney for Defendant 500 North Third Street, Twelfth Floor Harrisburg, PA 17101 ?_? ? W ?Y n1; ?,? ,- ? ? ? , . - ?• ^ - .... s ? ? i _?_, ? { «..,.. ?_ l ?? elf ._ ' EL? = c; J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ; CIVIL ACTION-LAW DIVORCE SHANNON KAUTZ, Defendant NO. 03-688 CIVIL TERM CERTIFICATE OF SERVICE I, Erin L. Benson, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Affidavit of Separation by placing the same in the U.S. Mail to Robert Lieberman, attorney for Shannon Kautz at the following address: 500 North Third Street, Twelfth Floor, Harrisburg, PA 17101. Date: ? ' /0,3 f C- -k ?- Erin L. Benson Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 1. P? .p ` _.. ? 7 J. FRANK KAUTZ, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 03-688 SHANNON KAUTZ, : CIVIL TERM Defendant : IN DIVORCE PETITION FOR RELATED CLAIMS UNDER DIVORCE CODE The petition of SHANNON KAUTZ, by and through her attorney, ROBERT B. LIEBERMAN, ESQUIRE, respectfully represents that: 1. Petitioner is the Defendant 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. Defendant requests this Court to preserve her right to have all marital property of the parties equitably distributed. 4. Defendant 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. Defendant requires reasonable support to adequately maintain herself and to pay the obligations of the parties. 6. Defendant requests this Court to preserve her right to seek an award of reasonable temporary alimony and/or financial assistance to pay existing obligations and to award alimony following a Decree in Divorce. 7. Defendant has employed Robert B. Lieberman, Esquire as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 8. Defendant requests the Court to allow her equitable distribution of marital property, reasonable counsel fees, costs and expenses, pursuant to the Divorce Code and Rules of Civil Procedure and at final hearing to further award alimony and such additional sums to pay existing obligations 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 payments for existing obligations, counsel fees, costs and expenses. Respectfully submitted, DATED: 3 ' ?• 3?N RobertB. Lieberman, Esquire 500 N. Third Street, 12th Floor Harrisburg, PA 17101 (717) 236-1485 Attorney for Defendant J. FRANK KAUTZ, Plaintiff V. SHANNON KAUTZ, Defendant the foregoing Petition for Related Claims was served upon Plaintiff, by depositing same in the United States Mail, Postage Pre-Paid, addressed as follows: Erin L. Benson, Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 J RobertB. Lieberman, Esquire 500 N. Third St 12t` Floor IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 03-688 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE On this day of , 2003, I certify that a copy of -4 Harrisburg, PA 17101 (717) 236-1485 Attorney for Defendant ? 0 O 1 (° CT- O C7 - C f?.. -cs K J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE SHANNON KAUTZ, Defendant NO. 03-688 CIVIL TERM INCOME AND EXPENSE STATEMENT OF J. FRANK KAUTZ I verify that the statements made in this Income and Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. Date: 04// (,., to 3 1 01 aintiff INCOME Employer: 12-7- A ?+yT k t-) C. Employer's Address: ?b EQ'FoC.D fZb.. 0-AMP fbt-L M 1-10%1 Type of Work: p Env v E R 4 Payroll Number: -13°110 t Pay Period (weekly, biweekly, etc.): 13z w6rKLy Gross Pay per Pay Period: $ 200.00 Itemized Payroll Deductions: Federal Withholding $ 12.21 Social Security Local Wage Tax Z • 29 State Income Tax Co . 29 Retirement Savings Bonds Credit Union Life Insurance Health Insurance Other (specify) Net Pay per Pay Period: $ 358 -40 Other Income: Week Month Year (Fill in Appropriate Column) Interest Dividends Pension Annuity Social Security Rents Royalties Expense Account Gifts Unemployment Comp. Workmen's Comp. Total $ $ TOTAL INCOME $ EXPENSES Weekly Monthly Yearly Home (Fill in Appropriate Column) Mortgage/rent $ $ 232.50 $ Maintenance Utilities Electric -.00 Gas Oil Telephone 0.00 Water Sewer Employment Public transportation $ $ $ Lunch Taxes Real estate $ $ $ Personal property Income Insurance Homeowners $ $ $_ Automobile o 33.0 Life Accident Health _ Other _ Automobile Payments $_ Fuel Repairs Medical Doctor $_ Dentist _ Orthodontist _ Hospital Medicine _ Special needs (glasses, braces, orthopedic devices) Education Private school $_ Parochial school College _ Religious _ Personal Clothing $_ Food Barber/hairdresser _ Credit payments Credit card Charge account _ Memberships _ Loans Credit Union $ Miscellaneous Household help Child care Papers/books/magazines Entertainment Pay TV Vacation Gifts Legal fees Charitable contributions Other child support Alimony payments Other too. 00 $50.00 $ 00.00 _ 10.00 50.00 Ik.dO 2-5.00 300-00 25.00 U©.00 3$0.(10 Seo-sal SuQ?p? $ $4.0- $ Total Expenses $ $iZiB•i2 $ PROPERTY OWNED Ownership* Description Value H W J Checking accounts $ 2.0'a' N Savings accounts Credit Union Stocks/bonds Real estate Other Total INSURANCE 25 • ?o tt $ 01. OA Coverage* Policy No. H W C Company Hospital Blue Cross Other Medical Blue Shield Other Health/Accident Disability Income Dental Other * H=Husband; W=Wife; J=Joint; C=Child SUPPLEMENTAL INCOME STATEMENT (If you are self-employed or if you are salaried by a business of which you are owner in whole or in part, you must also fill out the Supplemental Income Statement.) (a) This form is to be filled out by a person (check one): [ ] (1) who operates a business or practices a profession, or [ ] (2) who is a member of a partnership or joint venture, or [ ] (3) who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, profession, corporation or similar entity: (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement. (c) Name of business: Address and Telephone Number: (d) Nature of business (check one) [ ] (1) partnership [ ] (2) joint venture [ ] (3) profession [ ] (4) closed corporation [ ] (5) other (e) Name of accountant, controller or other person in charge of financial records: (f) Annual income from business: (1) How often is income received? (2) Gross, income per pay period: _ (3) Net income per pay period: _ (4) Specified deductions, if any: _ ?1 Label (See L instructions A on page 21.) E Use the IRS L label. H Otherwise, E please print R or type. E Presidential Election Campaign (See paqe 21.) Filing Status Check only one box. Exemptions Department of the Treasury-Internal Revenue Service ?00 02 U.S. Individual Income Tax Return ? 1 (P) For the year Jan. 1-Dec. 31, 2002, or other tax year beginning 2002, ending Your first name and initial Last name If a joint return, spouse's first name and initial Last name ?aPy ,20 Home address (number and street). If you have a P.O. box, see page 21. Apt. no. 1A19 So City, town or post office, state, and ZIP code. If you have a foreign address, see page 21. y--uo not write or stapie in tltfs space. OMB No. 1545-0074 Your social security number SS'sao3 :190 Spouse's social security number Important You must enter your SSN(s) above. ' Note. Checking "Yes" will not change your tax or reduce your refund. You Spouse Do you, or your spouse If filing a joint return, want $3 to go to this fund? . ? ?Yes ? No ?Yes ?No 1 ? Single 4 ? Head of household (with qualifying person). (see page 21.) If 2 ?-,arried filing jointly (even if only one had income) the qualifying person Is a child but not your dependent, enter 3 I Marriad filing separately. Enter spouse's SSN above this child's name here. ? and full name here. ? 5 ? Qualifying widow e with d (? ependent child (year s use died ? See Rage 21. Ba Yourself. If your parent (or someone else) can claim you as a dependent on his or her tax 4= of boxes return , do not check box 6a , , , . . . . 6a and and d on b spouse eb c If more than five dependents, see page 22. Income Attach Forms W-2 and W-2G here. Also attach Form(s) 1099-R if tax was withheld. If you did not get a W-2, see page 23. Enclose, but do not attach, any payment. Also, please use Form 1040-v. Adjusted Gross Income For Disclosure, d Total. number of exemptions claimed 7 Wages, salaries, tips, etc. Attach Form(s) W-2 . . , , 8a Taxable interest. Attach Schedule a if required . . b Tax-exempt interest. Do not include on line 8a 18b I 1 9 Ordinary dividends. Attach Schedule B if required . . . . 10 Taxable refunds, credits, or offsets of state and local income taxes (see page 24) 11 Alimony received . . . . . . . . 12 Business Income or (loss). Attach Schedule C or C-EZ , 13 Capital gain or (loss). Attach Schedule D if required. If not required, check here ? ? 14 Other gains or (losses). Attach Form 4797 15a IRA distributions Z=_ b Taxable amount (see page 25) 16a Pensions and annuities - b Taxable amount (sae page 25) 17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E 18 Farm income or (loss). Attach Schedule F , 19 Unemployment compensation . 20a Social security benefits . 120a I - I - I b Taxable amount (see page 27) 21 Other income. List type and amount (see page 29) 22 Add the amounts in the far, n right column for lines 7 through 21. This is ourtotalincome ? 23 Educator expenses (see page 29) , , . , . 23 -- 24 IRA deduction (see page 29) . 24 25 Student loan interest deduction (see page 31) , . , . 25 .. 26 Tuition and fees deduction (see page 32) . . , , , 26 27 Archer MSA deduction. Attach Form 8853 . . . . . 27 28 Moving expenses. Attach Form 3903 . . , . 28 29 One-half of self-employment tax. Attach Schedule SE 29 ?- 30 Self-employed health insurance deduction (see page 33) 30 31 Sett-employed SEP, SIMPLE, and qualified plans , . 31 32 Penalty on early withdrawal of savings . 32 - 33a Alimony paid b Recipient's SSN ? 2?i 1 : G /? 33a ?"'"' 34 Add lines 23 through 33a . . . 35 Subtract line a4 from line 22. This is your adjusted gross income ivacy Act, and Paperwork Reduction Act Notice, see page 76. Cat. No. 12599G Dependents: (1) First name Last name (2) Dependent's social security number (3) Dependent's relationship to ou (t) it qualrfy?g child tnr chOd tax aedit see 22 ? 7 No. of ch9dren on 6o who: • hued with you • dk1 not Yve with You due to divorce or separedon. (see pfte 22) Dependents on ec not entered above Add rNktlberE on Mrtea above ? CC, 9 10 - 11 Q7- 19 21 22 /,- I /Y Farm Form 1040 36 Tax and 36 Amount from line 35 (adjusted gross income) . . . . . . . Credits 37a Check if: ? You were 65 or older, ? Blind; ? Spouse was 65 or older, ? Blind. ard Add the number of boxes checked above and enter the total here . . . . ? 37a C tion b If you are married filing separately and your spouse itemizes deductions or F , you were a dual-status alien, see page 34 and check here . ? 37b ? ed ny any 38 Itemized deductions (fromSchedule A) or your standard deduction (see left margin) line 37a or 37b or 39 . Subtract line 38 from line 36 who can be claimed as a 40 If line 36 is $103,000 or less, multiply $3,000 by the total number of exemptions claimed on dependent, line 6d. If line 36 is over $103,000, see the worksheet on age 35 . p see page 34. 41 Taxable Income. Subtract line 40 from line 39. If line 40 is more than line 39 enter -0- 9 All others: 42 , Tax (see page 36). Check if any tax is from: a ? Form(s) 8814 b ? Form 4972 Single, $4,700 43 Alternative minimum tax (see page 37). Attach Form 6251 . Head of 44 Add lines 42 and 43 . . . . . . . . . . . ? household, $6,900 45 Foreign tax credit. Attach Form 1116 it required- 45 . -- Married filing 46 Credit for child and dependent care expenses?Attach Form 2441) 46 jointly or 47 ?, '??" Credit for the elderly or the disabled. Attach 8, 6Te A 47 Qualifying widow(er), 48 . Education credits. Attach Form 8863 48 $7,850 49 Retirement savings contributions credit. Attach Form 8880 49 Married 50 Child tax credit (see page 39) . 50 filing 5 42 43 44 1 Adoption credit. Attach Form 8839 . 51 52 Credits from: a ? Form 8396 b ? Form 8859 . . . 52 - - / 53 Other credits. Check applicable box(es): a ? Form 3800 b ? Form 88oi c ? Specify 53 54 Add lines 45 through 53. These are your total credits 54 55 Subtract line 54 from line 44. If line 54 is more than line 44- antar -n- i Other 56 Self-employment tax. Attach Schedule SE . . - 56 Taxes 57 Social security and Medicare tax on tip income not reported to employer. Attach Form 4137 57 - r 58 Tax on qualified plans, including IRAs, and other tax-favored accounts. Attach Form 5329 if required 58 59 Advance earned income credit payments from Form(s) W-2 . . . 59 60 Household employment taxes. Attach Schedule H . • . 60 _ 61 Add lines 55 through 60, This is your total tax Payments 62 Federal income tax withheld from Forms W-2 and 1099 62 j 61 41 63 2002 estimated tax payments and amount applied from 2001 return 63 - j If :Y-- have a qua d t child child attach att 64 Earned Income credit (EIC) . 64 - - 6.5 Excess social security and tier 1 RRTA tax withheld (see page 56) 65 , , , Schedule J 66 A dditional child tax credit. Attach Fort 8812 . 66 - - 67 Amount paid with request for exten i t 67 fil , s on o e (see page 56) 68 Other payments from: a ? Form 2439 b ? Form 4136 c -? Form $885. 68 69 Add lines 62 through 68. These are your total payments - Refund " , ? 70 If line 69 is more than line 61, subtract line 61 from line 69. This is the amount you overpaid 69 4)a 70 Direct deposit? See page 56 71a Amount of line 70 you want refunded to you • ? 71a ? b Routing number g??g and fill in 71 b, ? c Type: t Gheckrng 0 Savings 71 c, and 71 d. Do- d Accc)unt number L fj j? Amount 72 Amount of tine 70 you want Mpliedto our 2003 estimated tart ? 72 YOU Owe 73 Amount you owe. Subtract line 69 from line 61 For details on how to pay, see page 57 ? 74 Estimated tax penalty see pa a 57) . 73 Third Party la; Do you want to allow another person to discuss this return with the IRS (see page 58)? [] Yes. Complete the following. ? No Designee Designee's Phone name ? Personal identification Sign li ars no. ? ( ) number (PIN) ? Under penalties of perjury, I declare that I have examined this return and accompanying schedules and statements, and to the best of m knowl and belief, they are true, correct, and complete. Declaration of preparer (other than taxpayer y edge ) Is based on all information f hi h r o w e, c p eparer has any knowledge. Joint return ? See page 21. Yo nature Date Your occupation ` Daytime phone number Keep a copy ' (_7Q g 74?- 0(4-1 for your use s signature. If a join rn, both must sin. Dat 9 Spouse's occupation records. M Paid signature Preparer's Dat ' Check if Preparers SSN or PTIN Preparer's self-employed El ' Use Only Firm s name (or yours if self-employed),' EIN address, and ZIP code Phone no. ( ) Form 1040 (2002) ti U.S. GOVERNME NT PRINTING OFFICE: 2002-490-538 MirAm 443 8 THE MetMffen it bal" fv i*" to tM hahm/I RRrew semi« OMR N0. 1545-0008 1 WALES, TMs, OTHER COMPENSATION -' 2 FEDERAL INCOME TAX WITH HELD N WICATION MUMBR V. EMPLOYEE'S SOCIAL SECUMTY NUMBER S SOCIAL I IECWTY WAGES 662. 3 35.62 25989 180-58-5203 4 SOCIAL SEC«Ilri TAX WfT1/IED E S NAME. ADDRESS. AND ZIP CODE - 4 1 .05 e MEDICARE WAGES AND TIPS 6 MEDICARE WITHED r 'S ATHLEISURE CORP. 662 03 IXIE HWY - T SOCIAL 1RITY TIPS . 9.60 ¦ ALLOCATED TIPS ORD, MI 48329 1o DENT CANE FNFFITS FR19T NAME ADD INITIAL LAST NAME - 11 NONDIIALiED PLANS J F KAUTY 12 ¦-6 126 SOUTH 2ND ST 14 OTHER WORMLEYSBURG, PA 17043 _ IS STA EMPIOYEEi STATE 1 NO. 1 STATE W TNS, ETCATE VICOME X 1/ EE . C Mtirem/Rt Flee - PA 06-112 598 662 .03 18 54 . . ! p NAME Copy 2 To,be filed with Employee's ST ATE, CITY or LOCAL tax return . 662.0 3 61 MIDDLE TOWN FORM W-2 Wage and Tax Statement 2002 Beat. of the Treasury - Internal Revenje Service FOLD AND TEAR ALONG PERFORATION f-. 71. C II u 1[ as If ?S 4 r?.I. ?:.? /.a r?tt.r I i.ti- ,:,;1'Ir.:.l•: E. t.:,-? ,..:? ? I .?:. , ,.. 1:•?.:•;;:I;;. ..? 92021245 O.I.45 C.' IJ DESCRIPTION RATE HOURS EARNINGS YEAR TO DATE co 1 I >I I W I I I I 1 '. I I 1 0. Cq n 1 I 1 I I 1 I 9 I I I 11 I I EARNINGS TAXES DEDUCTIONS CURRENT 3 ?;y ) () S r.: YEAR TO DATE 1 I I I I 1 I 1 I I 1 1 I I L I i I I I I 1 I 1 I I 1 I 1 I I I I I 1 1 { I I 1 1 I I NET PAY P4,.aV5 045P5 TAXES / DED YEAR TO DATE I I <•: 1 t!: f.? 1' I '.:'? I I y 't' '.? I .?dl I:? ??,;3? t?:L rA x F, y t.. ?r 1, ji 1 t '! I IP 1?7 1 :E IIN ?r' 1 I I i r I 1 f 1 l: I I 1 L. I L..._ .I i PAY PERIOD CHECK NUMBER AMOUNT OF CHECK BEGIN 9202:1.2451 E ... 77.T"°.; f`ai'r ?r R z f a ? ? '1- s '? Z -? x I? N• ? , v? , 1 ?,-, i z - , ie g L RY . p ZZA Kpi t $R1 RD z x NP ILL PA Z?01# 3<33 , f Pizza Hut, Inc. ZZa quantum Road --CH, PLEASE DETACH AND RETAIN PAY PERIOD BEGIN PR. PERIOD END E?7?f1t?M1pN Rio Rancho, NM 87124 if THIS STATEMENT O; YOUR ` I Tel. 1-800-843-4306 EARNINGS. AND DEDUCTIONS SOCIAL SECURITY NO. CHECKDATE 180,-585203 03/24/03 EMPLOYEE Ni+7v1E KAUTZ FRANK -°- ` ID ORO S:'> , J 1 2 HOURS. RATE DESCRIPTION CURRENT T_Y EAR-TO-DATE HOURS RATE -? FEDERAL TA 6450 1 . FICA/MED 2156 85198 SUI TAX 06 23 1 z PENNSYLVAN ?89 3146 CAMPHILL X81 584 '? `° _i !3 t? f 4, x 020 _ _ Pizza Hut, Inc CAMP HILL . ,pA, 371 DELIVERY PIZZA Ht?T= ' 38 ERFORD RA I' KARNS PRIME FANCY FOOD LTD 424 PNC BANK 60-1273/313 General Account Southcentral, PA 675 Silver Springs Rd. Mechanicsburg, PA 17055 Check No. 0102374 ***DIRECT DEPOSIT ONLY**bate 01/16/03 PAY THIS AMOUNT DIR I $********',OO B To The J, FRANK KAUTZ JR VOI *0eO orde r Of 126 S 2ND STREET VOI IWORMLEYSBURG PA 17043 ID AUTH kR OI F it of NOT NE' G0'11ABLE _*_ Ik * . _. _ . , _._._. _VO.Ip?X.'OI•DVQIDYO-ID-___-.-___-_ -._.. 70ID VOID VOID VOID VOID VOID VOID VOID VOID VOID W, I KARNS PRIME & FANCY FOOD LTD J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE SHANNON KAUTZ, Defendant NO. 03-688 CIVIL TERM CERTIFICATE OF SERVICE I, Erin L. Benson, Certified Legal Intern, Family Law Clinic, hereby certify that on this 17"' day of April, 2003, I am served a true and correct copy of the Income and Expense Form, Federal Tax Return and pay stubs by placing the same in the U.S. Mail to Robert Lieberman attorney for Shannon Kautz, at the following address: 500 North Third Street, Twelfth Floor Harrisburg, PA 17101. X7/63 Date 1il/h? '/11 Y 6 Erin L. Benson Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE SHANNON KAUTZ, Defendant NO. 03-688 CIVIL TERM OF J. FRANK KAUTZ Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct, to the best of his knowledge, information, and belief. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Plaintiff reserves the right to correct and/or supplement this Inventory to the extent that he acquires additional information regarding assets and/or liabilities. Date: 6 (a /?3 ASSETS OF PARTIES Plaintiff/Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( ) 1. Real Property ( ) 2. Motor Vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( ) 5. Checking accounts, cash ( ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities (X) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventories, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits - severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans ( ) 18. Pension plans (indicate employee contribution and date plan vests) ( ) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. Military/V.A. benefits ( ) 23. Education benefits ( X) 24. Debts due, including loans, mortgages held ( X) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Description Names of Number Of Propertv All Owners 1. $100 microwave J. Frank Kautz, Shannon Kautz 2. $30 dishes J. Frank Kautz Shannon Kautz 3. Approximately 12 vhs movies worth $40 J. Frank Kautz Shannon Kautz NONMARITAL PROPERTY Plaintiff/Defendant lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Description Number of Propert y Owner(s) 4. 1914 antique headboard J. Frank Kautz and bed frame PROPERTY TRANSFERRED Item Description Date of Consid- Number of Propert y Transfer eration NONE LIABILITIES Item Description Names of Number of Property All Creditors 5. $52 Gas Bill UGI Gas Utilities 6. $73 Electric Bill PPL Electric Reason for Exclusion Kautz family heirloom - gift to J. Frank Kautz from his mother prior to the marriage. Person to whom Transferred Names of All Debtors J. Frank Kautz Shannon Kautz J. Frank Kautz Shannon Kautz J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE SHANNON KAUTZ, Defendant NO. 03-688 CIVIL TERM CERTIFICATE OF SERVICE I, Erin L. Benson, hereby certify that on this 16' day of June, 2003, I am serving a true and correct copy of the inventory of J. Frank Kautz on counsel for Defendant, Robert B. Lieberman, at 500 North Third Street, 121 Floor, P.O. Box 1004, Harrisburg, Pennsylvania, 17108-1004 by first class U.S. mail. Date Erin L. Benson Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 CJ "-`? O C_ r_,: i r' T` ri5:'` __ G r_ `, -,,. ?, _ v ,-, c .: =_ FRANK KAUTZ, Plaintiff V. SHANNON A. KAUTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 03-688 CIVIL TERM PETITION FOR RULE TO SHOW CAUSE FOR LEAVE TO WITHDRAW Petitioner, the Family Law Clinic hereby petitions for rule to show cause for leave to withdraw from further representation of J. Frank Kautz, pursuant to Pa.R.P.C. 1.16(b)(4) and Pa.R.C.P. 1012(b), and in support therefore avers the following: On January 29, 2003, the Family Law Clinic met with, and agreed to represent J. Frank Kautz in the above captioned matter. At that meeting, a certified legal intern described to Mr. Kautz his responsibility to remain in contact with the Family Law Clinic to represent him appropriately in his divorce action. 2. The Family Law Clinic filed a divorce complaint on behalf of Mr. Kautz on February 14, 2003. 3. The Defendant's counsel filed a Petition for Related Claims on March 18, 2003. 4. Since July 2, 2004, Mr. Kautz has failed to maintain contact with the Family Law Clinic. Repeated efforts by the Clinic to contact Mr. Kautz to resolve his equitable distribution issues have been unsuccessful. Mr. Kautz has failed to reply to telephone messages and letters sent to him by the Family Law Clinic. 5. Due to Mr. Kautz's lack of availability, the Family Law Clinic is unable to properly represent Mr. Kautz. 6. The Family Law Clinic has mailed Mr. Kautz letters informing him of our intent to withdraw if he does not contact us. Mr. Kautz has not responded to these letters. Pursuant to C.C.R.P. 206(2), the Family Law Clinic has sought and received concurrence for this petition from opposing counsel, Robert Lieberman. 8. The Family Law Clinic will serve notice of this petition to Mr. Kautz at his current address: 691 Garden Drive, Apartment 1, Harrisburg, PA. 17011. WHEREFORE, the Family Law Clinic respectfully requests leave to withdraw from further representation of Mr. Kautz in this matter. Date: C L Respectfully Submitted, ??'lGx?6?cv 4ihacl Mac t Certified Legal Intern lJONYASe'M. PLACE R RT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 n ° h n ' -r j GJ mrn U ?r _ w r ` N 4 J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . v SHANNON KAUTZ, NO. 03-688 CIVIL TERM Defendant ORDER OF COURT AND NOW, this 13`x' day of October, 2004, upon consideration of the petition for Rule To Show Cause for Leave To Withdraw, a Rule is hereby issued upon Plaintiff and Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 10 days of service. BY THE COURT, Michael Macht Certified Legal Intern Thomas M. Place, Esq. Robert E. Rains, Esq. Lucy Johnston-Walsh, Esq. Anne MacDonald-Fox, Esq. Supervising Attorneys amily Law Clinic 45 North Pitt Street Carlisle, PA 17013 Attorneys for Plaintiff ,Xobert Lieberman, Esq. 500 North Third Street P.O. Box 1004 Harrisburg, PA 17108-1004 Attorney for Defendant :rc f+n ;?E. _ Ij _ IN THE COURT OF COMMON PLEAS OF J. FRANK KAUTZ, ; CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION- LAW V : IN DIVORCE SHANNON KAUTZ, NO. 03-688 CIVIL TERM Defendant CERTIFICATE OF SERVICE first Pa of I, Michael Macht, hereby certify that on this date I am serving a true and correct order of Court In Re: Petition For Rule To Show Cause For Leave To Withdraw, by mail, on the plaintiff, addressed as follows: J. Frank Kautz 691 Garden Drive, Apt. 1 Harrisburg, PA. 17013 Date: 0 I 1-1 Mice ace?LE? Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 J. FRANK KAUTZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION- LAW IN DIVORCE SHANNON KAUTZ, Defendant : NO. 03-688 CIVIL TERM PETITION TO MAKE RULE ABSOLUTE AND NOW, comes petitioner, The Family Law Clinic, and petitions the Court as follows: 1. Petitioner, The Family Law Clinic, is counsel of record for the above named Plaintiff, J. Frank Kautz. 2. Petitioner filed a Petition to Withdraw in this matter on September 27, 2004. On October 13, 2004, this Court issed a Rule to Show Cause. A copy of the Petition and Rule to Show Cause are attached hereto and incorporated herein by reference as "Exhibit A." 3. The October 13, 2004, Rule to Show Cause permitted either party to object to the Family Law Clinic's request to withdraw as J. Frank Kautz's counsel within ten (10) days after service. 4. A true and correct copy of the Petition and Rule to Show Cause was served upon the Respondent J. Frank Kautz, by first class mail, postage prepaid, at his last known address on October 18, 2004. A true and correct copy of the Petition and Rule to Show Cause was served upon counsel for Defendant on the same date. 5. More than ten (10) days has passed since the Rule was served upon the Respondent and Defendant's counsel, and no response or objection has been filed. WHEREFORE, the Family Law Clinic requests this Court to enter an Order permitting it to withdraw as counsel for J. Frank Kautz in this matter. VERIFICATION I verify that the statements made in the foregoing document 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. Respect ly, Date: ?, f e Mic ael Macht Certified Legal Intern JA:nn e aD ' ald-Fox Ly J ston-Walsh Thomas M. Place Robert E. Rains Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA. 17013 (717) 243-2968 if NOV 1 0 2004 J. FRANK KAUTZ, Plaintiff V. SHANNON KAUTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE NO. 03-688 CIVIL TERM PETITION TO MAKE RULE ABSOLUTE AND NOW, comes petitioner, The Family Law Clinic, and petitions the Court as follows: 1. Petitioner, The Family Law Clinic, is counsel of record for the above named Plaintiff, J. Frank Kautz. 2. Petitioner filed a Petition to Withdraw in this matter on September 27, 2004. On October 13, 2004, this Court issed a Rule to Show Cause. A copy of the Petition and Rule to Show Cause are attached hereto and incorporated herein by reference as "Exhibit A." 3. The October 13, 2004, Rule to Show Cause permitted either party to object to the Family Law Clinic's request to withdraw as J. Frank Kautz's counsel within ten (10) days after service. 4. A true and correct copy of the Petition and Rule to Show Cause was served upon the Respondent J. Frank Kautz, by first class mail, postage prepaid, at his last known address on October 18, 2004. A true and correct copy of the Petition and Rule to Show Cause was served upon counsel for Defendant on the same date. 5. More than ten (10) days has passed since the Rule was served upon the Respondent and Defendant's counsel, and no response or objection has been filed. WHEREFORE, the Family Law Clinic requests this Court to enter an Order permitting it to withdraw as counsel for J. Frank Kautz in this matter. VERIFICATION I verify that the statements made in the foregoing document 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: t ?t Respect ly, r Mic ael Macht Certified Legal Intern Anne a D `ald-Fox Lucy J ston-Walsh Thomas M. Place Robert E. Rains Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA. 17013 (717) 243-2968 ? l ? ! ,? ?"" ". ?,,a 1. ° 1 l4-' ,? ' r. s' ?? ? 4- t: ,1 ?, ) c.? ? ?) . N ?? :a? _„? nov I 2ooo J. FRANK KAUTZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION- LAW IN DIVORCE SHANNON KAUTZ, Defendant : NO. 03-688 CIVIL TERM ORDER OF COURT AND NOW, this day of , 2004, upon presentation and consideration of the attached Petition to Make Rule Absolute, the Rule entered upon the above named Plaintiff, J. Frank Kautz, by Order of court entered October 13, 2004, is hereby made ABSOLUTE and Petitioner, The Family Law Clinic, is withdrawn as counsel for the Plaintiff, J. Frank Kautz. BY THE COURT a 0 O ? H C) LL N ?.1 J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-688 SHANNON KAUTZ, Defendant IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Defendant, moves the court to appoint a master with respect to the following claims: ® Divorce N Distribution of Property ? Annulment ? Support ? Alimony ® Counsel Fees ? Alimony Pendente Lite P1 Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claim(s) for which the appointment of master is requested. 2. The non-moving party has appeared in the action personally. 3. The statutory ground(s) for divorc is 3301(c) -irretrievable breakdown. 4. Delete the inapplicable paragraph(s): (c) The action is contested with respect to the following claims: equitable distribution, divorce, legal fees and costs. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1/2 (days). 7. Additional information, if any, relevant to the motion: None Date: December 4, 2007 Name: Attorney for Defendant AND NOW, 20_, master with respect to the following claims: Esquire, is appointed BY THE COURT: MOVING PARTY NAME: Shannon Kautz ATTORNEY'S NAME: Robert B. Lieberman, Esquire ATTORNEY'S ADDRESS: 500 N. Third St., 12' Fl. P.O. Box 1004, Harrisburg, PA 17108-1004 Tel. No. 717-236-1485 PARTY'S ADDRESS AND TELEPHONE NUMBER IF NOT REPRESENTED BY COUNSEL: NON-MOVING PARTY NAME: J. Frank Kautz ATTORNEY'S NAME: _ ATTORNEY'S ADDRESS: J PARTY'S ADDRESS AND TELEPHONE NUMBER IF NOT REPRESENTED BY COUNSEL: 126 South Second Street Wormleysburg, PA 17043 Tel. No. 717-975-0669 r-a c°? ?? ?? , ? r..? ?. ?.? --; wr i --, ? ? :; :..? .x i 5.=;._ .... _. _S ` _?. h t+ Z J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 03-688 SHANNON KAUTZ, Defendant IN DIVORCE INCOME AND EXPENSE STATEMENT I hereby file the within Income and Expense Statement and verify that the information therein contained is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unworn falsification to authorities. Date: By: Shannon Kautz, Defendant INCOME AND EXPENSE STATEMENT OF SHANNON KAUTZ Employer JFC Staffing Address Transcore 7631 Derry Street Harrisburg, PA 17111 Type of Work C.S.R. #0435 Pay Period Weekly Gross Pay per Pay Period $ 422.00 ITEMIZED PAYROLL DEDUCTIONS Federal Withholding $ 28.86 Social Security $ 32.28 Local Wage Tax $ 7.39 State Income Tax $ 13.34 Life and Health Insurance $ 23.10 Net Income per Pay Period. $ 317.03 Support - Per Week $ MONTHLY EXPENSES Mortgage, Lot Rent + Water + Sewer $ 620.00 - 650.00 Electric $ 86.00 Gas $ 100.00 Trash $ Telephone $ 100.00 Automobile Insurance $ 42.00 Automobile Fuel $ 100.00 Doctors $ Medicine $ Clothing $ 40.00 Food $ 200.00 Hairdresser $ 20.00 Gifts $ 30.00 Credit Payments: Cable TV $ 100.00 Entertainment $ 50.00 Legal Fees $ Total Monthly Expenses $1,488.00 PROPERTY OWNED VALUE Checking Account $120.00 Savings Account $ 5.00 TOTAL $125.00 t? c_ } `T1 ° F J C c `? J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. NO. 03-688 SHANNON KAUTZ, Defendant IN DIVORCE INVENTORY Defendant files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Defendant verifies that the statements made in this inventory are true and correct, to the best of her knowledge, information, and belief. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Defendant reserves the right to correct and/or supplement this Inventory to the extent that she acquires additional information regarding assets and/or liabilities. Shannon Kautz, Defendant ASSETS OF THE PARTIES Defendant, Shannon Kautz, avers and states that there are no marital assets to be divided between the parties. r ?? DEC 12 2007 J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 03-688 SHANNON KAUTZ, Defendant IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Defendant, moves the court to appoint a master with respect to the following claims: X Divorce N Distribution of Property ? Annulment ? Support ? Alimony E Counsel Fees ? Alimony Pendente Lite N Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claim(s) for which the appointment of master is requested. 2. The non-moving party has appeared in the action personally. 3. The statutory ground(s) for divorc is 3301(c) -irretrievable breakdown. 4. Delete the inapplicable paragraph(s): (c) The action is contested with respect to the following claims: equitable distribution, divorce, legal fees and costs. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1/2 (days). 7. Additional information, if any, relevant to the motion: None Date: December 4, 2007 Name: Attorney for Defendant AND NOW, . 0_ l3 20d 1, e 6-Nd ejCL,0,& 72t Esquire, is appointed master with respect to the following claims: oz_e tf B U'.r H o a .? MOVING PARTY NON-MOVING PARTY NAME: Shannon Kautz ATTORNEY'S NAME: Robert B. Lieberman, Esquire ATTORNEY'S ADDRESS: 500 N. Third St., 12th Fl. P.O. Box 1004, Harrisburg, PA 17108-1004 Tel. No. 717-236-1485 PARTY'S ADDRESS AND TELEPHONE NUMBER IF NOT REPRESENTED BY COUNSEL: NAME: J. Frank Kautz ATTORNEY'S NAME: _ ATTORNEY'S ADDRESS: PARTY'S ADDRESS AND TELEPHONE NUMBER IF NOT REPRESENTED BY COUNSEL: 126 South Second Street Wormleysburg, PA 17043 Tel. No. 717-975-0669 J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 03-688 SHANNON KAUTZ, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Robert $. Lieberman, Esquire, Attorney for Defendant, Shannon Kautz, hereby certify that on this 'day of. , 2007, I did serve a true and correct copy of the Inventory and Income and Expense Statement of Defendant, Shannon Kautz, on Plaintiff, J. Frank Kautz, at 126 South Second Street, Wormleysburg, Pennsylvania, by depositing same in the United States Mail, postage prepaid, as follows: J. Frank Kautz 126 South Second Street Wormleysburg, PA 17043 Robert B. Lieberman, Esquire Five Hundred North Third Street P.O. Box 1004 Harrisburg, Pa 17108-1004 Attorney for Defendant } ? ` ? -- <.,;. r" %:? ?' '?? ? ? . ?? ?. t.!'f J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 03-688 CIVIL TERM SHANNON KAUTZ, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 14, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 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. §4904 relating to unsworn falsification to authorities. DATED: o? - I " D D - 1i_'__ SHANNON KAUTZ, Defendant C? o ? -ra ? y f?rl i ?? .'?? t?.! w C? ? ?ry }?? -i 6?° ?¢ .. C? CTS . ? FRANK KAUTZ, Plaintiff V. SHANNON KAUTZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-688 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST _ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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. § 4904 relating to unsworn falsification to authorities. DATED: -ZL 't,? SH ON KAUTZ, Defendant co rnrs " t . tT?1 J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 03-688 CIVIL TERM SHANNON KAUTZ, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 14, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 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. §4904 relating to unswom falsification to authorities. DATED: 6?/ FRANK KAUTZ, -- ` !,./Plaintiff r f Y J co c,.. nI J. FRANK KAUTZ, Plaintiff V. SHANNON KAUTZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-688 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE I . I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. DATED: U- J? ?-• RANK KAUTZ, ,' Plaintiff m -n r T7 -TI J. FRANK KAUTZ, Plaintiff V. SHANNON KAUTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-688 CIVIL TERM IN DIVORCE PRAECIPE TO WITHDRAW PETITION TO PROTHONOTARY: Please withdraw and discontinue the Petition for Related Claims filed on behalf of Defendant, Shannon Kautz, in the above captioned divorce action on March 18, 2003. Dated: February 11, 2008 Robert B. Lieberman, Esquire 500 North Third Street, 12'b Floor Harrisburg, PA 17101 (717) 236-1485 Attorney for Defendant C C= ? _ -TI Fn f, rrI r t -- 1 J. FRANK KAUTZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 03 - 688 CIVIL SHANNON KAUTZ, Defendant IN DIVORCE ORDER OF COURT AND NOW, this day of , 2008, the petition filed by the Defendant raising claims o equitable distribution, alimony, alimony pendente lite, and counsel fees, costs, and expenses, having been withdrawn by her counsel by praecipe dated February 11, 2008, and both parties having signed affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce can conclude under Section 3301(c) of the Domestic Relations Code, the appointment of the Master is vacated, and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. QBY O URT, , \ Gy1 Edgar B. Bayley P.J. cc: ? J. Frank Kautz Plaintiff ? Robert B. Lieberman Attorney for Defendant (2, 1 ts '? L Icc-c Cr) C? ca J. FRANK KAUTZ, Plaintiff V. SHANNON KAUTZ, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 03-688 CIVIL TERM PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 3301 (c) 3301-(d) (1) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of Complaint: February 25, 2003, on Defendant's attorney Robert B Lieberman, Esquire as evidenced by an Acceptance of Service filed in the Prothonotary's Office of Cumberland County on March 7 2003 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce Code: by plaintiff February 11, 2008: by defendant February 11, 2008 b.(1) Date of execution of the affidavit required by 3301 (d) of the Divorce Code: n/a (2) Date of filing and service of the plaintiff's affidavit upon the respondent: n/a 4. Related claims pending: None 5. Complete either (a) or (b) a. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: n/a b. Date plaintiffs Waiver of Notice in 3301 (c) was filed with the Prothonotary: February 11, 2008 Date defendant's Waver of Notice in 3301 (c) was filed with the Prothonotary: February 11, 2008 DATED: • '4 , Robert B. Lieberman, Esquire 500 N. Third St., 121h Floor P.O. Box 1004 Harrisburg, PA 17108-1004 (717) 236-1485 Attorney for Defendant , t'P! ... m .' ITT , r7,1 W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. J. FRANK KAUTZ AND NOW, lm y cl it 2008 , IT IS ORDERED AND VERSUS SHANNON KAUTZ, Defendant No. 03-688 CIVIL TERM DECREE IN DIVORCE DECREED THAT AND Plaintiff J. FRANK KAUTZ SHANNON KAUTZ ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, I DEFENDANT, 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; BY THE COU ATTES?j - - 0 Y J. PROTHONOTARY ??,, ?r ?- A