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HomeMy WebLinkAbout03-0770IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID G. BUTZ, Plaintiff vs. SANDRA C. RITTER-BUTZ, Defendant NO. 03-- tpo Ci,.iI CIVIL ACTION - LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree of Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you. When the grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ASSISTANCE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 AVISO PARA DEFENDER Y RECLAMAR DERECHOS USED HA SIDO DEMANDADO EN LA CORTE. Si desea defederse de las quejuas expuestas en las paginas siquientes, debe tomar accion con prontitud. Se le avisa que si not se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja o compensacion reclamados por el demandante. Usted puede perder dinero, o propiedades y otros derechos importantes Para usted. Cuando la base Para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court House, Carlisle, Pennsylvania 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO Y OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telefono: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID G. BUTZ, NO. Plaintiff : VS. CIVIL ACTION - LAW SANDRA C. RITTER-BUTZ, Defendant IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING DAVID G. BUTZ, being duly sworn according to law, deposes and says: 1. 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. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. t Date: 1/3 1 103 ?. David G. Butz IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID G. BUTTS, Plaintiff VS. NO. 01- n'7.0 SANDRA C. RITTER-BUTZ, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this -;2© day of iG? 2elo3, comes the Plaintiff, David G. Butz, by his attorney, G. Patrick O'Connor, Esquire, Office of G. Patrick O'Connor, Esquire, and files the following Complaint in Divorce whereof the following is a statement: 1. The Plaintiff, David G. Butz, is an adult individual who currently resides at 703 Alberta Avenue, Mechanicsburg, Cumberland County, PA 17050. 2. The Defendant, Sandra C. Ritter-Butz, is an adult individual who currently resides at 703 Alberta Avenue, Mechanicsburg, Cumberland County, PA 17050. 3. The Plaintiff and Defendant were married on or about September 3, 1988, and separated on or about January 25, 2002. 4. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. Both the Plaintiff and Defendant are sui juris and are citizens of the United States. 8. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. WHEREFORE, the Plaintiff request your Honorable Court to enter a decree divorcing the Plaintiff and Defendant absolutely. Respectfully submitted, G. Patrick O'Connor, Esquire Attorney for Plaintiff 3105 Old Gettysburg Road Camp Hill, PA 17011 Phone: 717-73 7-7760 VERIFICATION I, DAVID G. BUTZ, state that I am the PLAINTIFF in the above-captioned case and that the facts set forth in the foregoing are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa.C.S. Sec. 4904. David G. Butz Date: 0 O Q _ --p Q 0 a I DAVID G. BUTZ, Plaintiff/Respondent VS. SANDRA C. RITTER-BUTZ, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 03-770 DEFENDANT'S PETITION FOR EMERGENCY RELIEF AND NOW, comes the Defendant/Petitioner, Sandra C. Ritter- Butz, by and through her attorneys, Dissinger and Dissinger, and files the following petition for emergency relief directing the Plaintiff/Respondent to assist her in maintaining the State Farm life insurance policy and for an interim award of counsel fees for the following reasons: COUNT I 1. Defendant/Petitioner is Sandra C. Flitter-Butz, residing at 703 Alberta Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. Plaintiff/Respondent is David G. Butz, residing at 113 May Drive, Apartment 4, Camp Hill, Cumberland County, Pennsylvania. 3. The parties are the parents of two (2) children of the ages Ithirteen (13) and eleven (11). 14. Plaintiff/Respondent separated from Defendant/Petitioner on January 24, 2003, and has filed this divorce action. 15. Defendant/Petitioner is physically disabled by RSD and Irequires either a cane, a walker or a wheelchair, depending on the severity of her symptoms from day to day. 16. Defendant/Petitioner receives Social Security Disability in the amount of $893.70 per month. 7. Plaintiff/Respondent currently maintains and contributes to a life insurance policy with State Farm Life Insurance Company, which provides coverage for the Defendant/Petitioner and the parties' two (2) children, Tyler D. Ritter-Butz and Korbin P. Ritter-Butz at a cost of approximately $21.00 monthly. 8. Plaintiff/Respondent has threatened to terminate the All State life insurance policy, leaving the Defendant/Petitioner and the parties' children without lifE! insurance. 9. Defendant/Petitioner, because of her physical condition, will not be able to get an affordable life insurance policy on her life and therefore will not be able to insure the parties' children. I 110. The current policy costs $20.00 per month for $100,000.00 of life insurance on Husband, $100,000.00 of life insurance on Wife land $5,000.00 of life insurance for each child. 11. State Farm is willing to do a "change of name" on the policy because there is a divorce, but the cost will be $20.00 per month for $100,000.00 for just Wife and, for each child, due to their disabilities, they can be insured for the minimum amount of $25,000.00 at a cost of $20.00 per child per month. 112. Thus, it will cost Defendant/Petitioner $40.00 more per mmonth for less coverage than the current policy if she does a "change of name". 13. Further, it will be impossible for Defendant/Petitioner to maintain and contribute to the children's State Farm life insurance policy without financial assistance from Plaintiff/Respondent on behalf of the children. 14. Plaintiff/Respondent is able to pay this cost as he has, since separation, purchased a puppy, and since separation has begun paying for horse riding lessons at a cost of $25.00 per week for one of the parties' children and dog obedience lessons weekly at $99.00 for an eight (8) week. course. 15. The policy of insurance is due to be cancelled immediately WHEREFORE, Defendant/Petitioner :requests the Court to direct the Plaintiff/Respondent to maintain the State Farm life insurance policy on himself, Defendant/Petitioner and the children or allow Sandra C. Ritter-Butz to pay the premium to State Farm so that she and the children are covered by life insurance for a cost of only $20.00 per month for the family. COUNT II 1. Defendant/Petitioner is Sandra C. Ritter-Butz, residing at 1703 Alberta Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. Plaintiff/Respondent is David G. Butz, residing at 113 May Drive, Apartment 4, Camp Hill, Cumberland County, Pennsylvania. 3. Defendant/Petitioner is unable to pay counsel fees for having to bring this action as her sole income is Social Security Disability of $893.70 per month. 4. Defendant/Petitioner has borrowed money to pay her attorney. 5. Plaintiff/Respondent has appealed on Order of spousal support and child support. I6. Defendant/Petitioner is in need of interim counsel fees, lexpenses and costs to put her on equal footing with (Plaintiff/Respondent. 7. Plaintiff/Respondent is employed at: Woodland Nursing Home grossing about $50,000.00 per year and earning at least $3,270.00 per month net and is able to contribute to Defendant/Petitioner's counsel fees. 8. Plaintiff/Respondent has told Defendant/Petitioner that his new attorney would charge a retainer of $7,500.00. 9. Defendant/Petitioner seeks $1,000.00 counsel fees for having to bring this action. 10. Defendant/Petitioner requests an interim Order of counsel fees of $500.00 monthly. WHEREFORE, Defendant/Petitioner requests the Court to require Plaintiff/Respondent to pay her interim counsel fees in Ithe amount of $1,000.00 for having to bring this action because IDefendant/Petitioner cannot afford to pay these fees. Respectfully submitted, DISSINGER AND DISSINGER By: ?- Mary A.` Etter Dissingee Attorney for Petitioner Supreme Court ID #27736 28 N. 32nd Street Camp Hill, PA 17011 (7:17) 975-2840 VERIFICATION I, Sandra C. Ritter-Butz, 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. §4904, relating to unsworn falsification to authorities. Sandra C. Ritter-Butz, etit' ner DAVID G. BUTZ, Plaintiff/Respondent VS. SANDRA C. RITTER-BUTZ, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL, ACTION - DIVORCE NO. 03-770 CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for David G. Butz, Plaintiff/Respondent, by First Class United States mail addressed as follows: J. Paul Helvy, Esquire 218 Pine Street Harrisburg, PA 7.7101 Date: 51-)- Z Alm A_ Mary A. Etter Dissinger ` r c?<i ?; ?? `? =? 'T "' '-'C 7 F T ?"? ? ; C ?_.._ c a i {°_; ? ,y ? ? ? ?? ? v l L.. e rr (DAVID G. BUTZ, Plaintiff/Respondent Vs. SANDRA C. RITTER-BUTZ, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 03-770 ORDER OF COURT AND NOW, this qj?A day of)a 2003, upon consideration of Defendant's Petition for Emergency Relief, a hearing is scheduled for the l? day of ?f 2003 at /?.m. in Courtroom No. of the Cumberland County Courthouse. J. 5_29 <3 6Z'° ?,? DAVID G. BUTZ V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA SANDRA C. RITTER-BUTZ Defendant NO. 03-770 CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR ENTRY/WITHDRAWAL OF APPEARANCE TO: THE PROTHONOTARY OF SAID COURT Please withdraw my appearance on behalf of DAVID G. BUTZ in the above- captioned action. b0_.3 Dated Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 Please enter my appearance on behalf of DAVID G. BUTZ in the above-captioned action. Dated J. P u elvy, Esquire Ki i n & Gephart, L 2 ine Street, P.O. Box 886 Harrisburg, PA 17108 (717) 232-1851 Atty. I.D. #53148 o O vn c f ` !!?l C cr. - ril r y _ - rv DAVID G. BUTZ, PLAINTIFF/RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. SANDRA C. RITTER-BUTZ, DEFENDANT/PETITIONER 03-0770 CIVIL TERM ORDER OF COURT AND NOW, this day of June, 2003, following an in-court review, the petition of Sandra C. Ritter-Butz for an award of interim counsel fees against David G. Butz, IS DENIED. By Edgar B. Bayley, J. Paul Helvy, Esquire .41 For Plaintiff Aary A. Etter Dissinger, Esquire For Defendant :sal ' ?RK g OL•19?? 1) Cam. (23 ,T DAVID G. BUTZ, PLAINTIFF/RESPONDENT V. SANDRA C. RITTER-BUTZ, DEFENDANT/PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-0770 CIVIL TERM ORDER OF COURT AND NOW, this 6 O day of June, 2003, on a petition for special relief in which the parties have entered into a stipulation, IT IS ORDERED that the attached stipulation is made an order of court. By the Edgar B. Bayley, J. ?d. Paul Helvy, Esquire For Plaintiff /Aary A. Etter Dissinger, Esquire For Defendant sal `0V, i?? try ?'_ ?_ _` ;` ,? _ . , ':1 `r? ..1'LJ ;J ?? U? ? I MS. DISSINGER: The stipulation is that 2 Mr. Butz, who is the owner of State ]?arm Life Insurance 3 policy 13430397, will allow this policy to remain in force, 4 and he will name my client as irrevocable beneficiary of 5 his life insurance benefit until the youngest child of 6 these parties attains the age of 18 years of age or is out 7 of high school, whichever comes last. My client will pay 8 the premium on this policy to continue it in force, and Mr. 9 Butz will allow my client to continue to be an additional 10 insured on that policy, and she will pay the premium for 11 her policy. He will also allow her to continue to maintain 12 both children as riders on that policy, and he will not 13 change that. He will not remove her as an additional 14 insured, and she will pay the premiums for the riders as 15 well. 16 THE COURT: All pending further agreement or 17 order of court. 18 MS. DISSINGER: Yes, sir. 19 MR. HELVY; And with the understanding that 20 my client has no obligation to make any premium payments on 21 these policies and that if for some reason Ms. Butz does 22 not make the premium policies and the policy lapses that's 23 not a violation of this stipulation. 24 MS. DISSINGER: That's understood and 25 agreed. To the extent that the insurance company requires D 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11 DAVID G. BUTZ, Plaintiff VS. SANDRA C. RITTER-BUTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVII, ACTION - DIVORCE NO. 03-770 SANDRA C. RITTER-BUTZ, Plaintiff VS. DAVID G. BUTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 03-1574 PETITION TO WITHDRAW APPEARANCE TO THE HONORABLE, THE JUDGE OF SAID COURT The Petition of Mary A. Etter Dissinger, attorney of record for Sandra C. Ritter-Butz in both of the above-captioned matters, respectfully represents: 1. That her appearance for Sandra C. Ritter-Butz, was entered on April 8, 2003, by filing a Complaint i=or Custody. 2. On or about August 7, 2003, Petitioner, Mary A. Etter Dissinger, Esquire, requested that Sandra C. Ritter-Butz deposit an additional retainer with her office by August 30, 2003, in order to reduce Ms. Ritter-Butz's balance to $1,000.00 or less. 3. Since that time, the same request has been made verbally and in writing to Sandra C. Ritter-Butz. 4. As of December 2, 2003, Sandra C. Ritter-Butz has failed to deposit the requested retainer with Petitioner, Mary A. Etter Dissinger, Esquire, and she has failed to make payments on account i of services long past due rendered and on account of services rendered since that point in time. 5. Sandra C. Ritter-Butz has requested that her mother pay her bill, but her mother has no contractual obligation with Dissinger and Dissinger, and her mother has failed to make regular payments on account of Sandra C. Ritter-Butz. 6. Sandra C. Ritter-Butz has not been able to assist counsel in the presentation and preparation of her case. 7. The Petition is not interposed for purposes of delay, as Petitioner has no knowledge of any proceeding that is scheduled with the Court, or that is to be scheduled with the Court. WHEREFORE, Mary A. Etter Dissinger and Dissinger and Dissinger respectfully request this Honorable Court to grant her Petition to Withdraw her Appearance on behalf of Sandra C. Ritter- Butz in both of the above-captioned matters. Respectfully Submitted: DISSINGER AND DISSINGER ?a??ntrG ss ary A? Etter Dissinger, Petitioner VERIFICATIO24 I, Mary A. Etter Dissinger, verify that the foregoing facts 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. Mary A. Etter Dissinge VID G. BUTZ, Plaintiff VS. A C. RITTER-BUTZ, Defendant . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 03-770 A C. RITTER-BUTZ, Plaintiff VS. VID G. BUTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 03-1574 CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, do hereby certify that a copy of the foregoing document has been duly served upon Sandra _. Ritter-Butz, and J. Paul Helvy, Esquire, by depositing same in the United States Mail, postage prepaid, addressed as follows: Sandra C. Ritter-Butz 703 Alberta Avenue Mechanicsburg, PA 17050 J. Paul Helvy, Esquire 218 Pine Street Harrisburg, PA 17101 ' Mary A ]'Etter Dissinger C. <o 'TI U ES r i r - )AVID G. BUTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. PENNSYLVANIA ANDRA C. RITTER-BUTZ CIVIL ACTION - DIVORCE , Defendant NO. 03-770 ? 1NDRA C. RITTER-BUTZ , Plaintiff IN THE COURT OF COMMON PLEAS • OF CUMBERLAND COUNTY vs. PENNSYLVANIA VID G. BUTZ, CIVIL ACTION - CUSTODY Defendant NO. 03-1574 RULE s?..- ---- AND NOW, this ??/ msideration of the foregoing Petition upon Petition and on motion0ofrMary A. ter Dissinger and Dissinger and Dissinger, the Court grants a le on Sandra C. Ritter-Butz and J. Paul Helvy, Esquire, to show use why the appearance of Mary A. Etter Dissinger and Dissinger 3 Dissinger, for Sandra C. Ritter-Butz, should not be withdrawn. le returnable ten (10) days after service. BY ? COURT; l J. to a ? -ate V N V a , DAVID G. BUTZ, Plaintiff VS. SANDRA C. RITTER-BUTZ, Defendant SANDRA C. RITTER-BUTZ, Plaintiff Vs. DAVID G. BUTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 03-770 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 03-1574 MOTION TO MAKE RULE ABSOLUTE The Petition respectfully represents: 1. Petitioner is Mary A. Etter Dissinger, attorney with the firm of Dissinger and Dissinger, with a place of business at 28 N. 32?d Street, Camp Hill, Cumberland County, Pennsylvania. 2. Respondent is Sandra C. Ritter-Butz, residing at 703 Alberta Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 3. A Petition to withdraw Appearance was filed with this Honorable Court on June 10, 2004. 4. A Rule to Show Cause why the relief requested should not be granted was signed by the Honorable Judge Bayley on June 16, 2004. 5. The Rule to Show Cause of June 16, 2004, was served upon Sandra C. Ritter-Butz on or about June 21, 2004 (See copy of letter to Ms. Ritter-Butz attached as Exhibit "A"). 6. A copy of the Rule to Show Cause was served on J. Paul Helvy, Esquire, counsel for David G. Butz, on or about June 21, 2004 (See copy of letter to Attorney Helvy attached as Exhibit "B„). 7. No response has been received from Sandra C. Ritter- Butz. 8. No response has been received from J. Paul Helvy, Esquire. WHEREFORE, Petitioner, Mary A. Etter Dissinger, Esquire, requests the Court to sign the attached order permitting her withdrawal as counsel in these matters. Respectfully submitted: DISSINGER AND DISSINGER 'Mary AF Etter?ger, Petitioner Supreme Court ID # 27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 DISSINGER t, DISSINGER Camp Hill Offices: 717.975.2840/voice • 717.975.3924/fax Marvsville Offices: 717.957.3474/voice • 717.957.2316/fax June 21, 2004 Sandra C. Ritter-Butz 703 Alberta Avenue Mechanicsburg, PA 17050 Dear Ms. Ritter-Butz: Enclosed, find a copy of a Rule To Show Cause, dated June 16, 2004, issuing a rule upon you and J. Paul Helvy, Esquire, to show cause why I should not be allowed to withdraw my appearance on your behalf. Very truly yours, Mary A. Etter Dissinger Attorney at Law MAED:ml Encl. 2 File 4-03-504 Attorneys rat Lain EXHIBIT 28 North Thim -Second Street • Camp Hill, PA 17011 "A" 400 South State Road • Man,sville, PA 17093 DISSINGER k, DISSINGER Camp Hill Offices: 717.975.2840/voice • 717.975.3924/fax Marysville Offices: 717.957.3474/voice • 717.957.2316/fax June 21, 2004 DAVID G. BUTZ, Plaintiff Vs. SANDRA C. RITTER-BUTZ, Defendant SANDRA C. RITTER-BUTZ, Plaintiff VS. DAVID G. BUTZ, Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 03-770 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 03-1574 CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, do hereby certify that a copy of the foregoing document has been duly served upon Sandra C. Ritter-Butz and J. Paul Helvy, Esquire, attorney for David G. Butz, by depositing same in the United States Mail, postage prepaid, addressed as follows: Sandra C. Ritter-Butz 703 Alberta Avenue Mechanicsburg, PA 17050 J. Paul Helvy, Esquire 218 Pine Street Harrisburg, PA 17101 Date: 71-710 K? Mary At. 'Etter Dissinger, Petitioner r-? c; T ,: ? m C.','i. 1 -rjQ .? ?-- - 2- p. _ ... `'?', :':i ?.. -< DISSINGER t, DISSINGER Camp Hill Offices: 717.975.2840/voice • 717.975.3924/fax Marysville Offices. 7t7.957.3474/voice • 717.957.23t6/fax June 21, 2004 J. Paul Helvy, Esquire 218 Pine Street Harrisburg, PA 17101 RE: Butz v. Ritter-Butz Dear Mr. Helvy: Enclosed, find a copy of a Rule to Show Cause, dated June 16, 2004, issuing a rule upon you and Sandra C. Ritter-Butz to show cause why I should not be allowed to withdraw my appearance on behalf of Sandra C. Ritter-Butz. If you have any questions, please feel free to call my office. Very truly yours, Mary A. Etter Dissinger Attorney at Law MAED:ml Encl. 1 cc: Sandra C. Ritter-Butz File 4-03-504 Attoi-tieys at Lain EXHIBIT 23 North Thirty-Second Street • Camp Hill, 81,17011 "B" 400 South State Road • ,?larvsviiie, P.1 17033 c? JUL 0 6 20M DAVID G. BUTZ, Plaintiff Vs. SANDRA C. RITTER-BUTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 03-770 SANDRA C. RITTER-BUTZ, Plaintiff Vs. DAVID G. BUTZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - CUSTODY NO. 03-1574 ORDER AND NOW this JAL- day of , 2004, with no objection from J. Paul Helvy, Esquire, and with no objection from Sandra C. Ritter-Butz, the firm of Dissinger and Dissinger and the appearance of Mary A. Etter Doss: BY PHF J. v? v W4 ?)?'? 7?? hOpl ?+'biGPdOF?lO JJ/j:ln. p37-1 JO Renee K. Simpson Deputy Prothonotary Curtis R. Long Prothonotary ce of the protbowaarr i Off (Cumberlaub Cauutp John E. Slike solicitor ,77b CIVIL TERM ORDER OF TERMINATION OF COURT CASES TH DAY OF NOVEMBER 2007 AFTER MAILING TICS OF AND NOW THIS 5 CE RECEIVING NO RESPONS - THE ABOVE INTENTION TO PROCEED AND WITH PREJUDICE IN ACCORDANCE WITH PA CASE IS HEREBY TERN11NATED R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573