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DECREE IN
DIVORCE
AND NOW,
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,~11T IS ORDERED AND
DECREED THAT
L. LJlNDER , PLAINTIFF
'----------"-'_._.~.__._~.,"--_._--- .
AND
.LEQNliRD~G..__LANDER,_ .JR.____.___.. DEFE N DANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF' THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTlor~ For, WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
NONE. The terms of the Agreement dated January 19, 2001 are
incorporated but not merged into this Decree in Divorc .
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PROTHONOTARY
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MARVETTA L, LANDER
Plaintiff
IN TilE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTV
PENNSYLVANIA
vs.
LEONARD G. LANDER, JR.
Defendant
CIVIL ACTION
NO. "1'( 1;",4l,; I,'".'. \, I,,'
IN DIVORCE
ORDER OF COURT
AND NOW, 1")/\'II'I"'~ , upon
consideration of the attached complaint, it is hereby directed
that the parties and their respective counsel appear before ---- t'
\ \ it t'r \ y ,( '.,\ ( ( ;....j , \: ',1\ " the conci liator, at ~~ l{"II, ),"-( l')o/Ql', ~n
f1',('hh-r'(fv) In {(\tooth)]'....' day of ~b\:..r ..\ ,19{'~.-., , at
q'.~,() n.m" for a Pre-Hearing Custody Conference. At
such conference, an effort will be made to resolve the issues in
dispute; or if this 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,
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 by made at least 72 hours prior to any hearing or business
before the court. You must attend scheduled conference or
hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWVER 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.
CUMBER~AND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE PA 17013
717 249 3166
I
11\ MARVETTA L. LANDER
Plaintiff
II
I,
:11, LEONARD G. LANDER, JR.
I, Defendant
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Ii You have been sued in court. If you wish to defend against
'I the claims set forth in the following pages, you must take prompt
I action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your
children.
IN THE COURT OF COMMON
OF CUMBERLAND COUNTY
PENNSYLVANIA
PLEAS
vs.
CIVIL ACTION
NO,
IN DIVORCE
NOT ICE
or 0
DEFEND
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 at:
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, PA 17013-3387
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 TillS 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.
CLMBERLAND CUJNTY BAR ASSOCIATION
2 LIBERTY AVENUE
7~LI~k~ ~t6617013
MARVETTA L, LANDER
Plaintiff
IN TilE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
, LEONARD G. LANDER, JR.
Defendant
CIVIL ACTION
NO.
IN DIVORCE
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NOTICE OF RIGHT TO COUNSELING
You are one of the parties in the above captioned action in
divorce. By virtue of section 202 of the Pennsylvania Divorce
Code, it is a duty of the Court to advise both parties of the
availability of counseling and upon request of either provide both
parties a list of qualified professionals who provide such
services.
Accordingly, if you desire counseling a list of marriage
counselors is available in the Office of the Prothonotary at:
Office of the Prothonotary
Cumberland county Court House
1 Courthouse Square
carlisle, PA 17013-3387
Prothonotary
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II MARVETTA L. LANDER
,i Plaintiff
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IN TilE COURT OF COMMON PI,EAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION
NO. {It. '1';"1/; l.'t,..t' ( r~I."""
IN DIVORCE
LEONARD G. LANDER, JR.
Defendant
CONSOLIDATED COMPLAINT IN DIVORCE
1. Plaintiff is Marvetta L.
residing at 595 Geneva Drive,
County, Pennsylvania.
Lander, a citizen of Pennsylvania,
Unit 11, Mechanicsburg, Cumberland
2. Defendant is Leonard G. Lander, Jr. , a ci tizen of
Pennsylvania, residing at 125 Steelstown Road, Newville,
Cumberland county, Pennsylvania.
3. Plaintiff and Defendant are sui iuris and have been bonafide
residents of the Commonwealth of Pennsylvania for at least six
months immediately preceding the filing of this Complaint.
4. The parties are husband and wife and were lawfully married on
May 27, 1989, in Missouri.
5. The marriage is irretrievably broken.
6. Neither Plaintiff nor Defendant is in the military or naval
service of the united States or its allies within the provisions
of the Soldiers' & sailors' civil Relief Act of the Congress of
1940 and its amendments.
7. There has been no prior action for divorce or annulment
instituted by either of the parties in this or any other
jurisdiction.
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I 15. After ninety (90) days have elapsed from the date of the
I filing of this Complaint, Plaintiff intends to file an affidavit
I consenting to a divorce. Plaintiff believes that Defendant may
also file such an affidavit.
16. Plaintiff has been advised of the availability of counseling
and that Plaintiff and Defendant have the right to request the
Court to require the parties to participate in such counseling,
WHEREFORE, if both parties file affidavits to a divorce after
ninety (90) days have elapsed from the filing of this Complaint,
Plaintiff respectfully requests the Court to enter a Decree of
Divorce, pursuant to 3301(c) of the Divorce Code.
COUNT III
Request for Divorce Due to Irretrievable Breakdown
Under 3301{d) of the Divorce Code
17. The prior paragraphs of this Complaint are incorporated
herein by reference thereto.
18. The marriage of the parties is irretrievably broken.
19. After a period of two (2) years has elapsed from the date of
separation, Plaintiff intends to file her affidavit of having
lived separate and apart.
20. Plaintiff has been advised of the availability of counseling
and that Plaintiff and Defendant have the right to request the
Court to require the parties to participate in such counseling.
WHEREFORE, if two (2)
separation and Plaintiff
respectfully requests the
pursuant to 3301(d) of the
years have elapsed from the date of
has filed her affidavit, Plaintiff
Court to enter a Decree of Divorce,
Divorce Code.
WHEREFORE, Plaintiff requests the Court to enter an award of
alimony pendente lite until final hearing and thereupon to enter
an Order of alimony in her favor.
COUNT VI
Request for Counsel Fees, costs and Expenses Under
3104, 3323, 3502(e) and 3702 of the Divorce Code
28. The prior paragraphs of this Complaint are incorporated
herein by reference thereto.
29. Plaintiff has employed Mary A. Etter Dissinger, Esquire of
the law firm of Dissinger & Dissinger to represent her in this
matrimonial cause.
30. Plaintiff is unable to pay the necessary counsel fees, costs,
and expenses and Defendant is more than able to pay them.
WHEREFORE, reserving the right to apply to the Court for
temporary counsel fees, costs and expenses, prior to final
hearing, Plaintiff requests that, after final hearing, the Court
order Defendant to pay Plaintiff's reasonable counsel fees, costs
and expenses.
COUNT VII
Request for confirmation of custody Under
3104 Divorce Code
31. The prior paragraphs of this complaint are incorporated
herein by reference thereto.
32. Plaintiff is Marvetta L. Lander, residing at 595 Geneva
Drive, Unit 11, Mechanicsburg, Cumberland County, pennsylvania.
33. Defendant is Leonard G. Lander, Jr., residing at 125
Steelstown Road, Newville, Cumberland county, Pennsylvania.
34. Plaintiff seeks custody of the following child:
Name
Present Residence
Age
Rachel M. Lander
595 Geneva Drive, Unit 11
Mechanicsburg, PA
8 years
old
35. The child was not born out of wedlock.
36. The child is presently in the custody of Plaintiff who
resides at 595 Geneva Drive, Unit 11, Mechanicsburg, Cumberland
County, pennsylvania.
37. During the past
following persons at
five years, the child has
the following addresses:
resided with the
Person
Address
Date
Marvetta L. Lander
Leonard G. Lander, Jr.
125 Steelstown Road
Newville, PA
1993
10/2/98
Marvetta L. Lander
595 Geneva Drive,Unit 11
Mechanicsburg, PA
10/2/98
to
Present
38. The mother of the child is Marvetta L. Lander who currently
resides at 595 Geneva Drive, Unit 11, Mechanicsburg, Cumberland
county, Pennsylvania.
39. She is married to Leonard G. Lander, Jr.
40. The father of the child is Leonard
G. Lander, Jr. who
Newville, Cumberland
I currently resides at
County, Pennsylvania.
125 Steelstown Road,
41. Hs is married to Marvetta L. Lander.
42. The relationship of Plaintiff to the child is that of mother.
The Plaintiff currently resides with the minor child.
43. The relationship of Defendant to the child is that of father.
The Defendant currently resides alone.
144. Plaintiff has not participated as a party or witness, or in
another capacity, in other litigation concerning the custody of
the child in this or another court.
45. Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
46. 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.
47. The best interest and permanent welfare of the child will be
served by granting the relief requested because Plaintiff has been
the primary caretaker since birth and has ben responsible for
providing a stable and nurturing environment in which to raise the
child.
48. Each parent whose parental rights to the child has not been
terminated and the person who has physical custody of the child
have been named as parties to this action. All other persons,
named below who are known to have or claim a right to custody or
visitation of the child will be given notice of the pendency of
this action and the right to intervene: None.
49. Defendant shall have the right to reasonable and liberal
visitation with the child.
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98 - 5746 CIVIL TERM
MARVETTA L. LANDER,
V5.
LEONARD G. LANDER, JR.,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 5 3301 (c) of the Divorce Code was filed on October 7,
1998,
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in 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 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, 4904 relating to unsworn falsification to authorities,
./- /~ ~~
c:9 Leonard G. Lander, :lr., Defendant
Date: /'>///9/';;)
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
!i3301 Icl OF THE 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 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. 4904 relating to unsworn falsification to authorities,
:-~~/.-A ~~
Leonard G, Lander, Jr., Defendant
Date:
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98 - 5746 CIVIL TERM
MARVETTA L. LANDER,
Y5.
LEONARD G. LANDER, JR..
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1, A Complaint in Divorce under 5 3301(cl of the Divorce Code was filed on October 7,
1998,
2, The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final Decree in 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 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. 4904 relating to unsworn falsification to authorities,
. /l--Lnf2,u-rJ1d --LuA_lt/\
Marvella L. Lander, Plaintiff
Datt:rA /0, ) nO /
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301 leI OF THE 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 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, 4904 relating to unsworn falsification to authorities.
l~mtlt.~u-J:t& ~ dLt0--
Marvetta L. Lander, Plaintiff
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: MARVETTA L, LANDER
, Plaintiff
IN TilE COUflT OF COMMON PLEAS
OF CUMBEIlLAtlD COUNTY
PENNSYLVANIA
;i
vs.
CIVIL ACTION
NO. 98-5746
IN DIVORC~;
'I LEONARD G. LANDER, JR,
II Defendant
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I COMMONWEALTH OF PENNSYLVANIA
AFFIDAVIT OF MAILING
ss
COUNTY OF CUMBERLAND
Mary A. Etter Dissinger, Esquire, the attorney for Plaintiff,
being duly sworn according to law, says that she mailed by
certified, restricted mail, return receipt requested, a true and
correct copy of the Plaintiff's Complaint in Divorce in this
action to the Defendant at his residence, and that Defendant did
receive same as evidenced by the signed receipt attached hereto as
Exhibit "A".
'----?fl /~ ~
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Mary A. Etter Dlssing~
Attorney for Plaintiff
28 North 32nd Street
Camp Hill, PA 17011
717-975-2840
Sworn to and subscribed
before me this 19~ day
of October, 1998.
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-tary Public
NOT M1AL S!Al.
CAROLENE E, SAN11AGO, Notary I'u""
Camp N;H Goto, Cumborlond Co.. ,,,
My Commloolon bpi... April 30. 2001
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NDER:
-Complele ilems 1 anG'or 2 to, additionalletVicel,
-Complele items 3, 4a, and 4b.
-Print your name and addre" on the reverie ollhil form so that we can ,eturn lhis
card to you,
-Attach this 'arm 10 lhe Irani of the maJlpieC8, orcntha back if space does not
permit.
-Wrile 'Rerum RfJC6ipt R9questoo' on the mai/piece below the article number.
-The Relurn Receipt will show 10 whom lhe article was delivered and Ihe dale
delivered.
3. Article Addressed to:
, also wish to receive the
fOllowing services (for an
exlre 'ee): Ii
1, 0 Addressee's Address ~
2,l!irAeSlricted Delivery ~
Consult postmaster for fee. *
4a. Article Number ai
z: l;;l'-f OfOS'" .5"03 ~
4b. Service Type t
o RegIstered a:
Cl
o Express Mail ~
o Return Receipt 'or Merchandise :
7. Date DeUvery .s
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S. Received By: (Print Name)
Domestic Return Receipt
EXHIBIT "A"
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LeOIldrd (;, Ldtld(~r, ,Jr., un Oc't'lhl'r le, If){J/i.
Till' Coil'\. ion
that we are l1!;lIlq i!i <)OiIlfJ to b(~ the Cdpt i()1l Ii If!d wi Lh the
cumplainl by wIlt'. ('on';t'qllt'lllly, lhl' OUll'l oIcllon lilt'd by
husband will have to be di!iCUnLlIIUt!d itnd w'e! Cilll (Jo UIl the
record later wilh Mrs. Lander as to whelher or nol she concurs
with the discontinuance ot the action which was [lled by her
husband.
After discussion this morning Mr. and Mrs.
Lander have reached a setllement with regard to the
outstanding economic issues. The agreement is going to be
placed on the record in the presence of the parties. The
agreement as placed on the record will be considered the
substantive agreement of the parties not subject to any
changes or modifications except for correction of
typographical errors which may be made during the
transcription. The parties and Ms. Lindsay will return later
this morning to review the draft of the agreement for
typographical errors, make any corrections as required, and
then affix their signatures to the agreement affirming the
terms of settlement. In any eve~t, the parties will be bound
by the settlement upon the statement on the record and will
not be able to make any substantive changes when they leave
the hearing room today. After the agreement has been
completed, the Master will prepare an order vacating his
appointment which will allow counsel for husband to file the
pr(J('("lfH' to t fdll:;rtllt 111(' fl'C'ord to ttll' ((l\lrt [I'qlJI':;llllq a
1111<11 df'CI('f.' III divorct'.
r-1r:i. I.lnd~;dY.
r-1:;. LIN!)~;^Y: TlH' pdft 11':; lid'll' d<lII'I'd to it
di~Lr ibu! l011l rd 'liPl r .1:;:;('1:; d:i !ull()VI:j:
1. Thl~ marilal home hds been ~iold dnel thert' i:; d
deficiency payable on the marital home to U:;UA of ~2, ~UO.OO
which has been paid by husband.
2. Wife will retain the 1989 Toyota Camry. Husband ~Iill
execute any and all documents necessary to transfer title of
that vehicle to her within ten days of the date of this
agreement.
Husband will retain the Ford F-150 1989 pickup. Wife
will execute any and all documents necessary to transfer any
interest that she may have in that vehicle to husband within
ten days of the date of this agreement.
The vehicles described are insured under a single
automobile insurance policy and the parties within ten days
will make arrangements so that wife has her own insurance and
husband has his own insurance on those vehicles.
3. Further husband will retain the Chevrolet Camara which
he is purchasing from wife's mother and which is presently
titled in the name of husband and wife's mother.
4. The parties will retain their own bank accounts, any
kinds of investments, intangible personal property which they
may have, including their own retirement benefits,
specifically husband will retain his pension with the state
Employees' Retirement System.
5. The household goods have been satisfactorily divided
with one exception and that is that husband has in storage
certain household goods. These goods are stored at the home
of Les Freehling in Mechanicsburg, Pennsylvania, within thirty
days of this date. Wife may take any of those household goods
which she would require. After thirty days, husband shall be
free to dispose of them so that they are no longer in Mr.
Freehling's basement.
6. With regard to liabilities, husband shall pay the joint
marital debt totalling $13,978.78 and he will also pay the
Memher':i l:i!. obi iqdt.io[j HhlCh i~; ill vJiff~':i Ildllll' dud fllr ....'IlIC'h
he i~j co-:;i(JIH~r In L!H' ddt(~ of :.;(!pdrdtiol} dtfl01JIll of ~4, IH,i,r.q.
Within thi rty ddYl; of till' dilt" of thll; '''lrc''lT'''lll hll:;h,II111 will
llIilke iJrrdIlqellll'nl:, for pdyrnunt. of Uldt dlPUlIllt wit.h !~(llllb(tr ':: l:it.
so thilt wi fe no lOllqer hd:i i111'l cxpu:_;ur(! lor pdYlTjI'nt (il t hdt
obi i <Jilt i un.
'/. In dddiLioIl, tlll:,biJlH.i recl~ive:i credit. for hl:; Wd;.:ill(J of
the mortqaqe payments on the r.ldritill home lor il pCrIod 01 Ii'
months when neither party rf.!:'jided therein and it certaIn cost
of sale and maintenance of the house, the electricity in the
house pendinq its sale.
8. The parties agree that they have incurred no obliqation
from June 13, 1998, for which the other may be liable ilnd if
any such obligation has been incurred by one party obliqatinq
the other party since June 13, 1998, they will indemnify and
hold the other party harmless on account of thilt obligation.
Having said that, the parties believe that they have divided
all their liabilities as of the date of separation.
9. Commencing February 1, 2001, husband will pay to wife
alimony in the amount of $250.00 per month through the office
of Domestic Relations through a wage attachment. Husband's
obligation for alimony pendente lite will terminate January
31, 2001. The alimony payments are non-modifiable except
upon the death of each party and specifically are not
modifiable in the event of wife's cohabitation or her
remarriage.
(A discussion was held off the record.)
10. 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, statutory allowance, widow's
allowance, right of intestacy, right to take against the will
of the other, and right to act as administrator or executor in
the other's estate. Each will at the request of the other
execute, acknowledge, and deliver any and all instruments
which may be necessary or advisable to carry into effect this
mutual waiver and relinquishment of all such interest, rights,
and claims.
THE MASTER: Marvetta, have you been present
':'"~;:;^~;'':'''''
dur in'J tile :;tiJl_ernent of the agreement on tile record?
111\5. I.ANlJl':fI: Yes.
TilE MASTEl<: Do YOII have any que:itions about
the agreemenL il:] sLuLed on the reco[ci':
MRS. LANDc~R: What was just put on record,
correct; is that what you are talking about?
TilE MASTER: Correct. What she stated as the
agreement, do you have any questions about the agreement that
she stated on the record?
MRS. LANDER: Just the fact that you had said
that he was supposed to pay me the $300.00. That was not put
on there. Is he just going to do that now and that will be
put on the record or how is that going to be done?
THE MASTER: Well, that is not included.
Perhaps we ought to state that because there was a $309.00
payment that was to be made.
MS. LINDSAY: Off the record.
IA discussion was held off the record.)
MS. LINDSAY: We had a misunderstanding as to
an obligation from husband to wife and husband agrees to
equalize the distribution and that within ten days of the date
of this agreement he will pay directly to wife $309.00.
THE MASTER: Having added that paragraph,
Marvetta, do you understand the agreement?
MRS. LANDER: Yes.
'1'111,: 1'./,,;n:H: [Jo you have i,ny qu,,:;Lion:; about
the aqrl'C'm(~flt..!
111<,:. I.ANll!-:l<: No.
TilE ;.l/,,;n:R: Allli d'e you );dtl:iiie'l L1lid. tld:;
agreement will settle and resolve all outstanding claims that
you have in this divorce action?
Mil,;. LANDER: Yes.
MS. LINDSAY: Len, you've heard the agreement
as I have dictated it today?
MR. LANDER: Yes.
MS. LINDSAY: And you also heard the waiver
that I read?
MR. LANDER: Yes.
MS. LINDSAY: Are these terms acceptable to
you?
MR. LANDER: Yes, they are.
MS. LINDSAY: Do you think you understand
them?
MR. LANDER: Yes.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend to
bind myself to the settlement as a contract Obligating myself
to the terms of settlement and subjecting myself to the
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~,,^RVFITA 1..I.ANIlUt
Plail1liff
IN TIlE ('( lllRT (JF ('(lMM(lN I'I./;AS (JF
('II~l/IU{I';\NIl ('( lllNTY, I'I;NNSYI. VANIA
v
('IV/I. A('T/ON - 1.;\ W
LEONARD (i. I.ANIlER. .lit
IlcJl:ndant
No. 'IX - 57-16 CIVIL
IN ('(]STO/)y
COli In OJUlE/{
AND NOW, this ..l~.... day or Il~~~mhl'r, 199X. upon ~onsidcration or thc aUachcd Custody
Conciliation Rcport, it is ordcr~d and dircctcd as /(llIolI's:
I. Thc Mothcr MarVClla L. Lan dcI' and thc Fathcr I.conard O. I.andcr. Jr. shall c'1ioy
sharcd Icgal custody oJ'HadwJ M. I.andc/', horn Novcmhcr 27, 19X9.
2. Thc Moth~r shall CI\;oy primar)' physical custody OJ'tllC minor child.
3. Fathcr shall cnjoy pcriods oj' temporary physical custody or thc minor child as
!(lllows:
A EvCI)' Monday cvcning Irorn 4:30 p.m. until X:OO p.m.
B. On altcrnating wcekcnds Irom Friday allcr work until Sunday at
8:00 p.m.
C. On a wcekly hasis on the Wcdncsday hclorc thc Fath~r has weckend
custody Irom Wcdncsday alier work until Thursday morning, and on
the Wednesday helorc the weckcnd the Fathcr docs not havc custody
trom Wcdncsday allcr work until Friday morning.
D. At such oth~r timcs as agrccd upon by the partics.
4. Each party shall be al10rdcd 3 wceks oJ'vacation with the minor child, which may
bc takcn in lip to 2 consccutivc wceks. Thc partics shallnotiJ'y the other party at
Icast 30 days in advance as to whcn thcy desirc to exercisc vacation time, and the
parties shall allempt to accommodate each othcr with respect to insuring that thc
vacation docs not intcr/erc with thc other parti~s vacation schcdule or othcr major
~ustody timc to thc extent possible hy the parties.
5. The pUl1ies shall alt~rnate holidays to indud~ New Ycar's Day, Mcmorial Day, July
41h, Labor Day. and Thanksgiving. The time Ihulle shall be 8:00 p.m. the night
helore the holiday until 8:00 p.m. on the day of the holiday. Father shall have New
Ycar's Day, 1999 with the parti~s altel11ating ther~alier.
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MARVETTA L. LANDER
Plaintif f
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
LEONARD G. LANDER, JR.
Defendant
CIVIL ACTION
NO. 98-5746
IN DIVORCE
PETITION FOR INTERIM COUNSEL FEES. EXPENSES AND COSTS
AND NOW comes Marvetta L. Lander by and through her attorneys,
DISSINGER & DISSINGER, and respectfully requests this honorable
court for special relief seeking an award of interim counsel fees,
expenses and costs and avers as follows:
1. Petitioner is Marvetta L. Lander, residing at 595 Geneva
Drive, Unit 11, Mechanicsburg, Cumberland County, Pennsylvania.
2. Respondent is Leonard G. Lander, Jr., residing at 125
Steelstown Road, Newville, Cumberland County, pennsylvania.
3. Plaintiff, Petitioner herein, has filed the complaint
alleging both fault and no fault grounds, including a count for
indignities under 3301(a) (6) of the Divorce Code.
4. The Defendant
Police as a state police
is employed by the Pennsylvania State
officer.
5. The Plaintiff in this case paid her counsel a $1,500.00
retainer to represent her in this divorce matter.
6, Unanticipated complications have arisen and the retainer
has long been consumed.
7. The complications with the divorce action are that the
Defendant filed a criminal complaint against the Plaintiff and she
had to obtain counsel to represent her at the questioning conducted
by the Pennsylvania State Police.
1\
8. No criminal charges were filed against the Plaintiff.
I 9. Defendant has denied Plaintiff's entitlement to spousal
I support and that matter is going to be scheduled for a hearing
before the Court on Defendant's denial of responsibility to support
Plaintiff,
10. The Defendant requested that the Plaintiff file a Bill of
Particulars.
11. The preparation of the Bill of Particulars consumed a
significant portion of the retainer paid to Plaintiff's counsel.
12. Another significant portion of the retainer was consumed
by having to have legal counsel present with Plaintiff at the
investigation by the Pennsylvania state Police.
13. The parties have engaged in custody conciliation and the
custody of the parties' minor child has been resolved by agreement
of the parties.
14. Plaintiff had to borrow the $1,500,00 retainer to pay to
her counsel.
15. Plaintiff does not qualify for any additional loans.
16. Plaintiff's income is insufficient to permit her to make
any payments on account of legal services rendered.
17. Plaintiff does not have any resources, nor income
sufficient to permit her to undertake an appraisal of the marital
residence which is subject to equitable distribution.
18, Plaintiff does not have resources or income sufficient to
have the household contents appraised for purposes of equitable
distribution.
II
19. Plaintiff anticipates the cost of appraisal of the real
estate will be approximately $450.00.
20, Plaintiff anticipates the cost of the personal property
appraisal will be approximately $300.00.
21, As of December 22, 1998, Plaintiff owed her counsel in
excess of $3,300.00, with no prospects of any ability to make any
payments on account in the near future.
22, Plaintiff has an agreement with her counsel that upon
failure to pay counsel's charges, counsel may terminate their
representation of Plaintiff.
23, Counsel has notified Plaintiff of her intention to
terminate representation for non-payment,
24. If Plaintiff's counsel terminates their representation
because of Plaintiff's non-payment for services and costs,
Plaintiff will not have the resources or income sufficient to
obtain new counsel to undertake her representation, nor have funds
to pay for costs of the appraisals, nor sufficient funds or assets
to pay new counsel to go through a support hearing before a Judge
in this Court, or to hire counsel to represent her in the divorce
matter.
WHEREFORE, Petitioner respectfully requests the Honorable
Court to award her interim counsel fees in the amount of $5,000.00
and $800,00 towards costs of appraisals,
Respectfully submitted,
DISSINGER & DISSINGER
By:
.. --?//(. ! 'i/-;'/i> -<
,/ / (.A:-t'_'-- {.I~_("" -l.r -{ I
Mary A. Etter Dissinger, Esquire
Attorney for Plaintiff
28 North 32nd street
Camp Hill, PA 17011
717-975-2840
MARVETTA L, LANDER
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
LEONARD G. LANDER, JR.
Defendant
CIVIL ACTION
NO, 98-5746
IN DIVORCE
CERTIFICATE OF SERVICE
I, Mary A. Etter Dissinger, Esquire, hereby certify that on
the date set forth below I served a true and correct copy of the
foregoing document upon the attorney for the Defendant, by First
Class united States mail addressed as follows:
Carol J. Lindsay, Esquire
FLOWER MORGENTHAL FLOWER & LINDSAY
11 East High Street
Carlisle, PA 17013-3016
Date:
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Mary Ai Etter Dissinger, Esquire
landor ... prp-trial sla:omonl
October 3. 7000
10 {"o<i
MARVETTA L. LANDER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98 - 5746 CIVIL TERM
vs.
LEONARD G. LANDER, JR.,
Defendant
IN DIVORCE
PRE-TRIAL STATEMENT OF
DEFENDANT. LEONARD G. LANDER. JR.
/, BACKGROUND
The parties hereto were married on May 27,1989 and separated on June 13. 1998. They
have one child. Rachel M. Lander, born November 27.1989. The child is presently in the custody
of the PlaintifflWife. Defendant/Husband has filed a Petition for Modification seeking custody of
Rachel. The hearing on that Petition is currently pending.
Husband is a Pennsylvania State Police officer. Wife is an employee of Rite Aid
Corporation. The last Court determination of Husband's salary attributed to him a net monthly
income of $3,400.00. Wife's gross annual income is $23.258.00, and her net monthly income is
$1,573.65, according to the most recent Order of Court. Husband pays to Wife $674.00 per
month for the support of Rachel. Husband also pays $200.00 per month in alimony pendente lite.
As the enclosed asset and liability list indicates, the parties have greater liabilities than
they do assets. During the period of separation. Husband has been servicing the joint debt In the
amount of approximately $576.00 per month.
At the present time. the most pressing issue is the marital home. The home was listed for
sale, but the listing agent withdrew when it became apparent that the first and second mortgages
could not be paid by any likely sale price for the house. Presently, Husband has found a private
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landor m pro-trial slalunlflnl
Or-Iolmf].7000
buyer and is attempting to secure Wife's agreement for the sale of the house. In order to do so,
he will have to borrow additional monies to clear the liens. In the meantime. neither party has
been residing in the marital home for a period of at least 11 months during which time Husband
has been paying the mortgage. Because of the serious financial situation in which the parties'
find themselves, and the ongoing drain to Husband's finances. it is especially important to bring
this matter to a prompt hearing.
II. ASSETS
Attached hereto as Exhibit "A" is a list of the parties' assets and their present values.
There are no non-marital assets with the exception of the non-marital portion of the Husband's
pension.
III. EXPERT WITNESSES
None anticipated.
IV. LA Y WITNESSES
Husband anticipates testifying on his own behalf and reserves the right to call other lay
witnesses if their testimony becomes relevant.
V. EXHIBITS
A. -Income and Expense Statement to be provided.
B. - Statement of Outstanding Marital Debt at the time of the parties' separation.
C. - Vehicle Values
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98 - 5746 CIVIL TERM
MARVETTA L, LANDER,
vs,
LEONARD G, LANDER, JR.,
Defendant
IN DIVORCE
STIPULA TION OF COUNSEL
The parties hereto, by their counsel. stipulate as follows:
1. The terms of this Stipulation were dictated in open Court on March 4. 1999 before
the Honorable Edward E. Guido. At the time of the Agreement. Marvetta L. Lander. Plaintiff.
hereinafter Wife, withdrew the Petition for Spousal Support entered to No. 803 S 1998.
2. Defendant, Leonard G. Lander. Jr.. hereinafter Husband, shall pay to Wife $200.00
per month commencing March 1, 1999. Said payments shall be made through the Office of
Domestic Relations of Cumberland County, Pennsylvania.
3. The obligation for payment of $200.00 per month is retroactive to October 1, 1998.
However, Husband shall not be obliged to make any payment on account of the arrearage until
resolution of the economic issues, and then in accordance with the terms of an Order of Court.
4. The Divorce Master shall consider that Husband paid on Wife's account $115.00 in
marital debt titled in Wife's name only for the period of October 1, 1998 through February 28,
1999. Said payments shall be a credit to Husband in equitable distribution.
5. This Order anticipates that Husband will be paying the automobile insurance on the
vehicle which Wife is driving until entry of the Decree in Divorce or further Order of Court.
? >1 '-v
"'-'-7)\ "--'-/ / c-cJ.,--,- /w-'- """"-7
Mary A. Etter Dissinger, Esquire
Attorney for Marvetta L. Lander
, !
1/ / :.
/ _ 1/, .'/ " /l~).:j({'l
Carol J.' LlJ;ldsay, Esquire
Attorney for Leonard G. Lander, Jr.
Date:
:~/7117
, "
Date: 'r'! i 'f '/'
, I
!\PR III
MARVETTA L. LANDER
PlainUtt
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSVLVANIA
CIVIL ACTION
NO. 98-5746
IN DIVORCE
VB.
LEONARD G. LANDER, JR.
Detendant
ORDER
AND NOW, this I 'i~ day of ~ ,2000, upon
review of the file and the Motion to be dismissed as Counsel
it is hereby ordered and decreed that Mary A. Etter Dissinger
and the firm of Dissinger & Dissinger is no longer Counsel of
Record for Marvetta L. Lander.
By the court:
~f~
'-1-/9-00
~K.s
landor on Polition tor modification May 8, 2000
MARVETTA L. LANDER.
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 98 - 5746 CIVIL TERM
vs,
LEONARD G, LANDER, JR..
Defendant/Petitioner
IN DIVORCE
PETITION FOR MODIFICA nON
NOW COMES Leonard G, Lander, Jr,. by and through his counsel, Flower, Flower &
Lindsay. P,C. and petitions this Honorable Court as follows:
1. The parties hereto are the parents of Rachel M. Lander, born November 27, 1989.
2. On December 16, 1998. the Court of Common Pleas of Cumberland County,
Pennsylvania, entered an Order for the custody of Rachel by an agreement of the parties. A
copy of this Court Order is attached hereto as Exhibit "A".
3. Petitioner is a member of the Pennsylvania State Police, and effective April 1,
2000 is reassigned from the Carlisle, Pennsylvania area to the area around Greensburg.
Pennsylvania.
4. Petitioner wishes to modify the terms of the Court's Order of December 16, 1998 in
light of the changed circumstances.
5. Petitioner believes and therefore avers that it would be in the best interest of the
child for Petitioner to have primary physical custody of her for the following reasons:
A. Petitioner is more emotionally stable than is Respondent.
B. Petitioner can best provide for the child's physical, emotional and
spiritual well-being.
C. The child is emotionally bonded to Petitioner.
',.
lander ... Petillon for mod,ficallnn May 8. 20110
MARVETTA L. LANDER,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 98 - 5746 CIVIL TERM
vs.
LEONARD G, LANDER, JR"
Defendant/Petitioner
IN DIVORCE
CERTIFICATE OF SERVICE
, I
AND now, this ':, day of // ,( (I/~ . 2000, I. Carol J.
Lindsay, Esquire, of the law firm of FLOWER, FL~WER & LINDSAY, P.C., Attorneys, hereby certify
that I served the within Petition for Modification this day by depositing same in the United States
Mail, First Class, Postage Prepaid, in Carlisle. Pennsylvania, addressed to:
Ms. Marvetta L. Lander
595 Geneva Drive, Unit 11
Mechanicsburg, PA 17055
FLOWER, FLOWER & LINDSAY
Attorneys for Defendant/Petitioner
In
" /
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C6i rr\ '\, /-:-~
i \Carol J. Lindsay, Esquire
'_ /lD # 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
By:
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~ Conrad l'vI. Siegel, Inc.
Carol J. Lindsay, Esq.
January 17.2001
Page 2
1. A maximum single life unnuity of $891.
2. A refund of his contributions plus interest and a reduced maximum single life annuity
of $626.
The following table shows the pension earned as of January 4, 2001, adjusted for retirement at
age 50, the present value of such benefits, the "coverture fraction" and the present value of the
pension earned during the marriage:
Pension
Benefit
Present Value
Pension Benefit
Coverture
Fraction
Present Value
Pension Earned
Durin!! the Marria!!e
Monthly full pension of
$891
$43,799
.75
$32,849
Refund of contributions
plus interest and
reduced monthly full
pension of $626
$47,258
.75
$35,444
The pension benefit earned as of January 4, 2001, takes into account 2.56 years of service after
the date of separation. Therefore, it is necessary to multiply the present value of the pension
benefit by a "coverture fraction" in order to determine the present value of the pension earned
during the marriage. The numerator of the "coverture fraction" is 7.49 (the years of service as
of the date of separation) and the denominatoris 10.05 (the years of service with the SERS as
of January 4, 2001), Thus, the "coverture fraction" is .75 (7.49 divided by 10.05).
It is my understanding that Leonard G. Lander, Jr. is not covered for Social Security benefits.
In accordance with the Cornbleth vs. Cornbleth decision, it is necessary to calculate what his
Social Security benefit would have been ifhe had been covered for this benefit. The estimated
Social Security attributable to the marriage to start at age 62 is $199 per month. This is based
upon his earnings previously indicated and assuming previous earnings increased in
accordance with the increase in the U.S. average salaries and taking into account an
appropriate "coverture fraction."
The present value of a monthly Social Security benefit of $199 for a male age 32 to start at age
62 is $4,444.
The following table shows the pension earned as of January 4,2001, adjusted for retirement at
age 50, the present value of the pension earned during the marriage, the present value of the
Social Security Offset and the net present value:
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I N 'I'm: COUl'.'J' ell-' (;( ):":'.U:I !'l.r:I,:; OF
(:IJ/1BI':HI,^NIJ COln;'j"(, l'I':~m::"'LVAN!A
V~; .
CIVIl. ACTION.. I.!I'/I
NO. (Hj - ~i '/ ~ l. C! V I L
1.I':ONAHil e;, l.ANIH':H, ,JH"
IJr! t endan t
IN I'J vcmn:
CONFEHENCI'; W I 'I'll
COUNSEL AND TilE PMn 1 E:;
TO: -..--............-....-......
Marvetta L. Lander
Counsel for Plaintiff
Plain Li rr
Carol J. Lindsay
Leonard G. Lander, Jr,
, Counsel for Defendant
, Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 19th day of January, 2001, at 9:00
a,m" with counsel and the parties to discuss the
outstanding economic issues to determine if there is a basis
of settlement of claims. If issues remain after the
conference a hearing will be scheduled at another date.
Very truly yours,
Date of Notice:
December 20, 2000
E. Robert Elicker, II
Divorce Master
-: --;.,_..:.;~.::.~..
..,. ........ ~. "J\\O . Q
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I I I V 7U I ~ . V,.} .'tV. ~ f "" """" I I....
LAml!ll
v. loAlr.l! P.
PACSES c;a,c Numbel: J80:JCJ54
Said r:1oney It' be lurned lwcr by the Domestic Relations Scccion to:
MA.1Vlr.":'A L. LANIl!R . Paymen15 must be mad~ by
O~P!NDAN':' , A!J checks and money orders m'.lS! ()~
m.1de payable to: DOMI!:STlC RBLATIOIlS SBCTIOll' and mailed to:
DOMESTIC RELATIONS SICTIOII' ~;
P.O. BOX 320. C.\RLISLE, PA. t7013
Each payment must bear your PACSES Member Number in ordl:r to be processed. Do no:
send cash by mail.
Unreimburscd medIcal expenses are :0 be paid GS % by defendant and 39 %
by plaintiff. 0 Defendant 0 Plainriff ONeilhcr palt'j to provide medical in5l!r~nCe
cov~ra!:e, Within thillY (30) days ~fter the entry of ~ijs order, the 0 Plaintiff
o Defendant shall submit ~o the person having custody of the child(ren) written proof that
medical insurance covera~e bas been obtained or that application for coverage has been mad:.
J'roof of coverage- shall consisc, at a minimum, of: I) the ~.ame of th~ health care coverage
provider(s); 2) any applicable identificacion numbers; 3) any cards evidencing coverage;
4) the address to which claims should be made; 5) a description of any restricti"n, on usage,
such as prior approval for hospital admissions. and the manner of obtaining approval;
6) .1 copy of the benet!t booklet or coverage contract; i) a descriptiofl of all deductibles and
co-payments: Jlld 8) five copies of any claim forms.
IMPORTANT LEGAL NOTICE
M.Rl1BS MUST WITHll'I SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND
THE OTHER PARTIES, l'I WRJTI.."l'O, OF ANY MATERIAL CHANGE IX ClRCUMST ANCES RELEV A.."IT
TO !HE LEVEL OF SUPPORT OR 11m ADMINISTRATION OF THE SUPPORT ORDER. IXCLUDIXG.
BUT :'lOT LIMITED TO, WSS OR CHANGE OF lXCOME OR EMPLOYMENT AND CHANGE OF
PERSONAL ADDRESS OR CHANGE OF ADDRESS OF A..1Ity CHILD RECEIVING SUPPORT. A PAk/)'
WHO WlUnUY FAlLS TO JlEPORT A MtlTERIAL CHANGE IN CIRCUMSTANCES MAl' iJE ADJt'DGED IN
COlm",PT OF COURT, AND M.4Y Bli .'1NED OR IMPJUSON71D.
Service Type M
P.~. 2 "f3
runQ OIi.SIB
Work~r 10 211 0 0
,.... ......, ..,oJ.... ...
'II 100'" \I .,
, "'v,'''' I" .IJ~ I'...."'. "'" ...,..w
LNIOIlR
PACSES C....'1umbor: 3801""4
\. I.;J.'CY.R
PEN'lSYLVANIA LAW PROVIDE~ THAT ALl. StiPPO;l.T 'JRDERS SHALL BE lllJVleWllO AT LEAST
ONCE EVERY THREE (31 YE,~RS tf SUCH RllVU:;W IS REOU:lSTED 'lY OSE OF THE PAKTJES, IF
YOU WISH TO REQUEST A R.EV:EW AND ADJtJSTMliNr OF YOL'1l ORDER. YOU MVST DO nm
r'OI.LOWING: CALL YO'JR ATIORNEY. AS UNREPRf.5ESTErJ PERSON \1,110 WANTS TO MODIFY
(ADJUST) A StJPPORT ORUER. SHO:;J.D CONTACT TlfE DOMESTIC RELATIONS SEC:TJO'l.
^ MANDATORY INCOME ATrACHMJ:NT WILL ISSUE tlNLESS TIlE DEFENDANT IS :-I()T JloI
A.lUtllARS IN PAYME." IN AN AMOUNT EQUAL TO OR GREATER THAN O:'lE MONTH'S SUPPORT
OBUGATlON A.'ll:> (II THE COL'RT FINDS THAT THEIl; lS GOOD CAUSE NOr TO REQl.'lRE
tM~.1SDIATE INCOME WITHHOLDING; OR m A \\'R.:1TEN .\GREEMSm lS R.EACHED BETWEE:-;
THE PARTIES W.tiICH PROVIDES FOR 041-1 Al.TERl\ATE ARRANGEME!':T.
DELNQL'ENT ARREARAGE 8ALA.'lCES MAY ar. REPCRTF.D TO CREDIT AGENCIES, ON AND
AFTER THE DATE IT IS DUE, EACH :''NPAlD SUPPORT ?AYMENT SHAlL CONS'JTl'1.:TE A
iL'DGMENT AGA.'NST YOU.
IT is FURTHER. ORDERED lhal. upon payor's failurc to comply with this order, payor may be
arrested and brought l>efore the Court for a Ccnt~mpt hearing; payor's wages. sala."Y.
commissions and/or income may be att8l:hcd in accordance with Jaw; thi~ Order wIll be
Increased wi!boUt further hearing to $ 500, oc a month un:i1 all arreamges are paid 10
full. Payor is responsible for coun tests and fees.
Copi., dcliver:i to porti..
Consented:
Plaintiff
Plallltiff's Attorney
Defendant
Defendam's Attorney
J,
F:d'lIl rd E. GuJ,do
Dne: l~'.1ei,llda E. She:.f.f.ct'
cc: pla1n~irr and jef~nd~nt
Ste?hcn" G. Held. gsq.
..)t>r\.i,,:: T)'pe M'
?:l!~e 3 of 3
FNID OE,SI8
Workcrff) 211CO
COMMONWEAL HI OF PA - EMPLOYE STATEMENT ."., .., --.....-. ""..... 'u" ..' nf Iv... .n .,..
GROSS EARNINGS 1,.U.Jt 41.912.31
'AV PIRIOD [WOING: 10"U." PA1 CAn: 10-]0-'1 MINUS OEDUCTIONS
VfI: ..2000"0000 DEP': 010 CDC: 01120 HO N'H T. N 00 711." 5.2...26
soe SEe/H[D rx 1..'000'4 17,0' 601.U
()4P1: 411U' POU: 01142' SSN: 0'.61-1890 SUIE NTH IX 'A 7.10000\ '1.10 1.11'. JI
I'U: Ll PU RANG I : 0\ SUP: E LEVEL: 01 tOC we U.fI(S 'A 21 '21 1. ??oo0\ 18.1' 41'.71
sun polleE CARllSL[ 5T"ION REf '/U CON HATE IMP ".00000\ n..n 2.0".11
FAIR $H FE[ FOp.PSTA 1000 '.21 101,\1
LEONARD G LANCER JR
'25 STEnSTOWN ROAD
NEWVILLE PA 17241
NET EARNINGS: 1,411.01
SIAIE 'AIO IENEfllS IHIS PAV PLUS REIMBURSEMENTS I
HEALTH IIENEFITS CAPITAL BLUE CROSS 114.U
LIFE INSURANCE 6.06
HORKERS COM' 37.17
HEAL TH/WELFARE n."
HEOICARE 21.07
RETIREMENT SIAIE EHPlOYE5 REI 5YS 386.71
'OlAl "0" 'olU S 610.40
, , > , ,,' PAID LEAVE "AIEHENI " ," , , , ',' , IOTAL OIECKAItOUHT : ',"; ," ,'" S 1,437.01 ,', ,
SERYICE CREDIT: 7 YR 21 PP
PP END <lEAVE U5AGE REPORIED '" HOUll5 PP END IREAKDOHN. GROSS EAR. HOURS ' RATE GROS5 '.
10-16-91 ANNUAL 7,00 10-16-98 REG SAL 80.00 23.17 1.1.53.60
10-16-'1 SICK 13.00 10-16-'1 SH OJ F-5% RT 11.00 1.16 12.16
< ,'..' ,TOTAL,GROS5 ,EARHIHGSlItIS:PAV7\,<,,: S ," '1,1lI66-.34'.
lrAYEACTlY,ITY, ,.' . ''. ' AHNUAL I, 51C!<.','.'.'. PEaS...l .,' :, <'i< .. SEHIORITY'INFOllMATlOH:" ...".
BALANCE LAST STATEMENT 370.77 78'.70 ( 8.001
ACCRUAL THIS PP 4.62 4.10 a.oo
LV REPORIEO IHIS PP 7.00 13.00 .00
AOJUSTHENTS .00 .00 .00
BALANCE THIS STHT 368.3' 781.50 .00
u.....,,:ACCRIlAl RAIE: ANNUAL '5.7 . 51C!< 6.00"< "",
HESSAGE CENTER: LOCAL MAGE TAX COUNTY/HUNICIPALITY: CUMBERLAND COUNTY NORTH HEHTOH THP
FHT TAX GROSS: 1.773.04
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\ MARVETTA L. LANDER
plaintif f
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
CIVIL ACTION
NO. 98-5746
IN DIVORCE
LEONARD G. LANDER, JR,
Defendant
BILL OF PARTICULARS
plaintiff hereby particularizes her grounds for divorce as
follows:
1. Approximately two years ago, while at the marital residence,
Wife would receive several calls per week, and when she would
answer the telephone, the caller would hang up.
2. Husband never got hang ups when he answered the telephone,
3. Once, Wife got a call from someone that sounded like a woman
who laughed into the telephone and hung up.
4. Wife called Husband at work after she received that call and
told him to tell his girlfriend not to call their home anymore
because wife was going to have the calls traced and thereafter
Wife never received another hangup telephone call,
5. On or about the morning of October 9, 1997, Husband told wife
he went from the parties' home in Newville to Carlisle to get the
truck of Sally Worst and changed the oil in Ms. Worst's truck.
6. In the afternoon of October 9, 1997, Wife called Husband and
asked him to put air in the tires of Wife's vehicle and Husband
was angry and did it begrudgingly.
7. witnesses to Husband's anger at having to put air in wife's
tires are: Diane Labelle and Jamie Macri.
!I
B.
wife told Husbilnd if he could not hilve time to work on her
he had no business working on ilnother womiln's car,
I car,
Ii
Ii 9. For
I! daughter
II
110. Christmas Day of 1997, the pilrties were opening presents at
Husband's family's house ilnd when their dilughter opened a present,
a dancing gorilla, Husbilnd silid to Wife he wanted to buy sally
Worst the same toy for Christmils beCiluse she would like that.
Christmils 1997, the pClrties hild spent $1,400.00
and agreed not to buy eilch other presents,
on their
11. Wife was distressed Husbilnd WilS considering buying Sally
Worst something and was troubled because Husband was thinking of
her on Christmas Day, and not ilbout Wife and his family and Wife
was distressed he could consider buying a present for Sally Worst
when Husband and Wife agreed not to buy each other presents.
12. On December 26, 1997, Husband told Wife
arrangements to go with Wife to meet Sally Worst,
and Kirk's then girlfriend Lori in Pittsburgh that
he had made
Kirk Perkins,
evening,
13. When Husband and Wife arrived in Pittsburgh, Kirk Perkins and
Lori were there as well ilS SilIly Worst, her sister, and a friend
of Sally Worst,
14. Wife had never met Sally Worst's sister or her friend before.
I 15. The group went to
Worst sat by Husband,
a bar at approximately 8:00 p,m, and Sally
16. For 1-1/2 hours, Husband and Sally Worst monopolized each
other's time to the exclusion of Wife.
17. After 1-1/2 hours, Husband turned to Wife and said "You're
not talking," to which \;1 fe repl ieel, "Maybe because I have no one
"l<
I!
I,
,
,
,
I
I to talk to, II whereupon Husband turned
I his conversation with Sally Worst,
,
"
"
[, 18.
bar
had
his back on Wife and resumed
At about 10:30 p.m" Kirk Perkins and his girlfriend left the
and Husband wanted to take Sally Worst and Wife to a bar he
been to in downtown Pittsburgh.
19. The group went to the bDr in two CDrs, with Sally Worst
driving her own car,
20. Wife complained to Husband in their car about him
her and paying attention to Sally \vorst all evening,
denied he ignored Wife,
ignoring
Husband
21. When the two groups arrived at the bar, Husband went into the
bar with Sally Worst and left \vife behind to enter with sally
Worst's sister and friend, and then he waited for Wife at the
counter to pay for her admission.
22. There were no tables available, so Husband, Wife and the
others stood around and listened to the band.
23. As the group stood, Husband and sally Worst stood together,
about a foot apart engaged in conversation and Wife stood four or
five feet from them.
24. sally Worst's sister and friend visited with each other.
25. Husband made no effort at this bar either to include Wife in
any conversation,
26. After about 20 minutes of embarrassment, anger and being
ignored by Husband, Wife told Husband she was going to another
part of the bar and he followed reluctantly and Sally Worst stayed
with her sister and friend.
27. Wife and Husband stood toyether and listened to the music and
watched the dancing,
28. Husband decided he and IHfe woulJ leave and Husband and Wife
went to tell Husband's friends.
29. When Husband and Wife left, Husband walked sally Worst to her
car and left Wife to walk forty feet (40') behind, never once
turning to see where Wife was or if she was safe.
30. After Husband saw Sally Worst to her truck, Husband waited
for Wife and the other couple to catch up to him at Sally Worst's
truck door.
31. Husband and Wife then walked to their vehicle,
32. Wife and Husband exchanged no words for the half hour drive
to his parents' home,
33. In Husband's parents' residence, Wife said to Husband "Do you
realize you did it to me again"?
34. Husband said, "What do you mean?"
35. Wife said, "You did it to me again."
36. Husband said, "I do not know what you are talking about."
37. Wife said, "You walked her to her car and did not even bother
to see where I was, or if I was safe." Wife told Husband he was
so engrossed in Sally Worst, he did not even notice Wife.
38. Husband told Wife she was being ridiculous and all were
walking as a group and Husband thought they were all in a group.
i'
I
i 39.
![' his
, she
Wife told Husbilnd not to treut her thilt WilY ilgain and that
friendship with Sillly Worst was making her uncomfortable and
wanted Husband to stilY ilWilY from sally Worst.
"
1140.
i'
,
,
I 41. On New Year's Eve 1997, Husband ilnd Wife for the
I in seven years went out on New Year's Eve to
i Mechanicsburg.
I
Husband made a gesture of disgust ilnd walked out of room.
first time
Wandas in
42. When Husband
by Sally Worst at
down by Husband,
Sally Worst.
Wife arrived, Husband went directly to sit
table and Wife followed Husband. Wife sat
and
her
who was already engaged in conversation with
143.
I
I 44.
I 45.
them, in their words,
Husband ignored Wife the entire evening,
Witnesses to that are John Yunk and Michelle Dagen.
John Yunk and Michelle Dilgcn told
Wife to spend time
talking to you."
11 because he's not
46. John Yunk and Michelle Dagen told Wife a couple of times that
evening they could not believe how Husband and Sally Worst acted
together in public and in Wife's presence,
47. Husband danced with Sally Worst several times that evening,
48. When Husband and Sally Worst danced, they had their arms
around each other,
49. When Husband and Sally Worst were seated at the table, they
had their arms around each others' shoulders laughing and swaying
to the music.
with
II
I
!
II
il
I
I 60. Husband got ilnqry
I "ridiculous agilin",
I
I
I
I
with
\oJife ilnd
told her she being was
she hild told him several times
with Sally Worst made her
lIusbilnd she had asked him before
61. Then Wife renlinded lIusudnd
before that his friendship
uncomfortable, and she reminded
to stay away from Sillly \-Iorst.
62. Husband said to Wife "1'lhGtever".
63. Wife was dressed and made up her best and for one of the
first times in her life WGS proud of her appearance,
64. When Husband and \-life arrived at their table, they put Wife's
purse and coats on their seats.
65. Shortly after Husband and \-life arrived, sally Worst and Kirk
Perkins arrived at the table and for the first time in Wife's
presence, Sally Worst didn't sit beside Husband,
66. Since on or about June 1997, Husband has asked Wife to get to
know sally Worst because "she's such a nice girl",
67. Since about June 1997, Husband and wife went out at least
every other week and on every ene of these occasions, Sally Worst
joined Husband and Wife and en all but two of those occasions,
until January 3, 1998, Husband and Sally Worst sat side by side.
68. Immediately after the January 3, 1998 dinner, Husband and
Wife were mingling with the crowd from 9:30 p,m to 11:30 p.m. They
would visit with friends and rejoin each other.
69. During that interval en January 3, 1998 frem 9:30 p.m, until
11: 30 p. m" Sally Werst and Husband were together for all but
approximately 15 minutes ef that time,
;1
70, At dinner on JilnUiH'Y 3, 1998, Huc:bilnd c:poke with Wife on
I
i occasion who WilS at his side, but he spoke more frequently with
: Sally worst, who was not seated next to Husbilnd.
I
,
I
171.
and
At about 11:30 p.m.
Sally Worst were no
on January 3,
longer in the
1998, Wife
ball room,
noticed Husband
72. Wife waited and waited for Husband and Sally Worst to
reappear and they did not. At 12: 00 a. m" Wife told Michelle
Dagen she was going to the bar to look for Husband, and she told
Michelle Dagen she'd bet she would find Husband with sally Worst,
73.
they
Michelle Dagen and Wife walked to the bar and at 12:00 a.m"
found Husband and sally Worst seated together side by side on
a love seat.
74. Wife because angry
from Sally Worst, and
ballroom.
because she had told Husband to stay away
she left the bar and returned to the
75. Wife said to Michelle Dagen, "I can't believe he did this to
me."
76. Wife went to John Yunk and asked him to take Wife home and
said she had told Husband to stay away from Sally Worst and he
wasn't able to do it for one night.
77. John Yunk said he'd get Husband out of the bar.
78, Husband returned to the ba 1 Iroom fuming and angry he was
called away from Sally Ivorst and the bar.
79. Husband went and <Jot Hi Ie'" CQ"t "lid threw it on the table in
I front of Wife and "aid, "I'm leavill(J alld if you're coming, you
better come now,"
80. When Husband and Wife left the ballroom to go home on January
3, 1998, Husband walked about twenty feet (20') ahead of Wife.
81. When Husband and Wife got to car, IHfe yelled at Husband, "I
can't believe you did it to me again. I told you to stay away
from her and you couldn't stay away from her for one night,"
82. Husband said, "What are you talking about,"
83. Wife said she watched Husband all night and Husband and sally
Worst had been together all night except once when she found him
with sally Worst in the bar on a love seat.
84. Wife cried the whole way home, yell ing, "how could you do
this to me...I told you to stay away...I told you your
relationship with her made me uncomfortable..."
85. When Husband and Wife got home, IHfe told Husband if he
wanted Sally Worst that badly, he could get his things and leave,
to which Husband replied, "OK" and he packed personal belongings
and left.
Respectfully submitted,
DISSINGER & DISSINGER
B~'^-'y tVA-d,
Mary A. Etter Dissin~er, Esquire
Attorney for Plaintiff
28 North 32nd Street
Camp Hill, PA 17011
717-975-2840
VERIFIC1ITION
I, Milrvettil L. Lander, verify that the forc'loing facts are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa,C,S. 54904, relating to
unsworn falsification to authorities,
\t;~~f2~hhn 'iC( I yJ.P/)
Milrv tta L. Lilnder
I
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MARVETTA L, LANDEIl
Plaintiff
I II TilE COUH'I' OF COMMON PLEAS
OF CUl-IllEHLMlD COUNTY
PEII1IBYLVANIA
VB,
LEONARD G. LANm:H, J({,
Defendant
CIVIL ACTIOII
110, 9!l-!i746
111 III VO({CE
CERTIFICATE OF SERVICE
I, Mary A, Etter Dissingcr, Esquire, hereby certify that on
the date set forth below I served a true and correct copy of the
foregoing document upon the attorney for the Defendant, by First
Class United states mail addrcsscd as follows:
Carol J, Lindsay, Esquire
FLOWER MOHGENTIIAL FLO~lER & LINDSAY
11 East High Street
Carlisle, PA 17013-3016
Date: II flip /9 J-
,
~~o~~
~Iary A. E ter Dissin r,Equire
- - - -+-
".
. .. - ~.."_.. . .
,
-
MARVETTA L. LANDER
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
CIVIL ACTION
NO. 98-5746
IN DIVORCE
vs.
LEONARD G. LANDER, JR.
Defendant
CERTIFICATB OF SERVICB
I, Mary A. Etter Dissinger, Esquire, hereby certify that on
the date set forth below I served a true and correct copy of the
attached Rule upon Marvetta L. Lander and Carol J. Lindsay,
attorney for the Defendant, by First Class united States mail
addressed as follows:
Marvetta L. Lander
595 Geneva Drive, Unit 11
Mechanicsburg, PA 17055
Carol J. Lindsay, Esquire
FLOWER, FLOWER & LINDSAY
11 East High Street
Carlisle, PA 17013-3016
Date: ..3 / I / t,;rV
~ "--7 {)&t~ I;
Mary A. Etter D~ss~~er
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WHEREFORE, Petitioner prays that a Rule be granted upon the
Defendant and Carol J, Lindsay, attorney for Defendant to show
cause why the appearance of Petitioner, acting for Plaintiff in
this case, should not be withdrawn.
/1'.. 'I' .'(~1. ,,,11/ ','" , /' ".,_
Mary A. Etter Dissinger,~etitioner
~.~-.-;.t.-.
COMMONWEALTH OF PENNSVLVANIA
ss
COUNTY OF (: <I "/,,, ,I,,, " l
Before me a Notary Public in and for said County and state,
personally appeared MARY A. ETTER DISSINGER, Esquire, who being
duly sworn according to law, deposes and says that the facts set
forth herein are true and correct to the best of her knowledge,
information and belief.
'----""".
,/,
Mary
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A. Et~er Dissinger'
Sworn to and subscrlbed
before me this 7 I ? day
of .:X),-c e",L. v' ,1999.
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a /'...(r.-.. j' c.
Notary Public
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~OLEN~ P.. :;'~:-nJC '. ~:
Celf:.,,,, ~n;o ,~O, ~,r! ,I;' "': ..... .
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____..___..1
lander .... pelition for roconsidor.alion March e, lnnn
MARVETTA L. LANDER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98 - 5746 CIVIL TERM
Plaintiff
vs.
LEONARD G. LANDER, JR.,
Defendant
IN DIVORCE
PETITION FOR RECONSIDERA TlON
NOW comes Leonard G. Lander, Jr., by and through his counsel. FLOWER,
MORGENTHAL, FLOWER & LINDSAY, P.C.. and moves this Honorable Court to reconsider its
Order of February 25, 1999.
1. On December 4, 1998, Plaintiff above filed a Petition for Special Relief seeking
counsel fees and expenses averring as a reason therefore the filing of a Bill of Particulars which
was "unnecessary and designed to harass her and her counsel and increase her attorney's fees."
2. On December 9, 1998. without a hearing, this Honorable Court denied the Motion
stating "when a party pursues a divorce under Section 3301(a) or (b) of the Divorce Code, the
other party may secure a Bill of Particulars as a right" and citing therefore Pa.R.C.P.1920-21.
3. The Bill of Particulars filed in response to the Rule of the Defendant was 85
paragraphs in length and highlighted. as grounds for the divorce, hang up phone calls which she
had received, and Defendant's alleged ignoring her at three social occasions at the end of 1997
and the beginning of 1998. The Bill of Particulars contains details such as "Paragraph 64. When
Husband and Wife arrived at their table. they put Wife's purse and coats on their seats."
4. A copy of the Bill of Particulars provided is attached hereto as Exhibit "B".
"
~
I
,
,I
!
lander... potltion for roconsitJoralion March 8. 1999
5. On January 22. 1999, Plaintiff again filed a Petition for entering counsel fees,
expenses, and costs, averring, inter alia, the frivilous filing of a Bill of Particulars.
6. After a hearing on February 25. 1999, this Honorable Court ordered Defendant to
pay to Plaintiff $750.00 to "defray fees for the preparation of a Bill of Particulars".
7. At the hearing on February 25.1999, Defendnat did not justify the Rule for the Bill of
Particulars because the Court had, on December 9. 1998. already determined that the Bill of
Particulars was a matter of "right". Movant reasonably believed that any argument on the
issuance of a Bill of Particulars had been decided by the Court's Order of December 9, 1998.
8. Had Defendant presented evidence on the appropriateness on the Bill of
Particulars. it would have included the following:
A. Plaintiffs filing of a fault ground for divorce was frivilous.
B. The Bill of Particulars was unnecessarily exhaustive, detailing dates and
times for acts that were not or could not have been construed to be indignities.
C. Defendant could have filed Interrogatories seeking the same information, that
is the grounds for any claim for a marital misconduct.
9. The information sought in the Bill of Particulars is important as marital misconduct is
a factor in alimony and in spousal support. Plaintiff had filed for spousal support and had filed, in
her Complaint for Divorce, a count for alimony.
10. The evidence of Defendant's income and expenses adduced at the hearing on
February 25,1999 is that after payment of marital debt, the mortgages on the marital home, taxes
and insurance, and child support. Husband has $477.00 per month to pay for insurance, utilities,
food. cloihing, and his own attorney's fees. Neither party has savings, investments, or other
liquid assets.
By:
, i
, /
! i ,'J /'! _
I 0./( (V, I--:r..~
) Carol Tttndsay
/ ID # 44693
11 East High Street
Carlisle. PA 17013
(717) 243-5513
landor... potition for roconsideration March 8. 1mm
11. On March 4. 1999, Plaintiff withdrew her Petition for Spousal Support and, by
agreement of the parties, an Order of alimony pendente lite in the amount of $200.00 was paid by
Defendant to Plaintiff was stipulated in open court.
12. Although Husband can effect a savings to himself of $115.00 per month by not
paying two marital debts which are tilled in Wife's name alone, after the payment of alimony
pendente lite. his disposable income will have been reduced to $292.00.
13. Movant believes, and therefore avers, that he reasonably relied upon the Court's
Order of December 9, 1998 in presenting his case, and determined that the issue of attorneys'
fees attributable to the Bill of Particulars was inappropriate.
WHEREFORE, Petitioner prays this Honorable Court to reconsider its Order of February
25, 1999, and to issue a Rule upon Respondent to show cause why the relief requested here
should not be granted.
FLOWER, MORGENTHAL FLOWER & LINDSAY, P,C.
Attorneys for
Date: {.t i (C~ c.A" 'f.l ." ~/l
. -:-.~-;'::-;-,~ "
LEONARD G. LANDER JR
PACSES MCIllh.:r NUIllhc:r: 9701100108
PAYMENTS MUST INCLUDE TIlE DEFENDANT'S NAME AND TilE PACSES
MEMBER ID OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED. DO
NOT SEND CASH BY MAIL.
This order of attachment for support is binding upon you until furthcr noticc and shall have
priority over any attachmcnt. execution. garnishment or wage attachment under state or local
law except one relating to a prior support order. You must commcnce thc attachment of the
defendant obligor's income as soon as possible but no later than fourteen days from the date
of the issuance of this Order of Attachment.
You are notified further that pursuant to law:
1. The defendant obligor has been notified that an order of attachment for support would
be issued.
2. Willful failure to comply with this order may result in (i) your being adjudged in contempt
. of court and committed to jailor fined by the court; (ii) your being held liable for any
amount not withheld or withheld but not forwarded to the Domestic Relations Section; and
(iii) attachment of your funds or property.
3. The attachment of income or the possibility thereof as a basis. in whole or in part. for the
discharge of an employee or any disciplinary action against or demotion of an employee is
prohibited. Violation may result in (i) your being adjudged in contempt and committed to
jailor fined by the court and (ii) an action against you by the employee for damages.
4. If there are in your employment one or more additional employees whose incomes are
subject to an attachment of support. you may combine the attachment payments into a
single payment to the Pa SCDU and separately identify the portion attributable to each
obligor.
5. You must notify the Domestic Relations Section or the Pa SCDU when the defendant
obligor terminates employment and provide the Section with the employee's last known
address and the name and address of the new employer. if known.
Page 20f3
FornI EN-028
Worker 10. $IATT .
Service Type M
..', ..--....,..
LEONARD G. LANDER JR PACSES Melllher Numher: 9701100108
6. The maximum amount of the attachmcnt shall not excced 50 % of thc cmploycc' s
nct income which is within thc limits sct in thc Consumcr crcdit Protcction Act, 15
lJ.S.c. * 1673.
7, The term "income" as defincd by law includcs compcnsation for services. including, but
not limited to, wages, salaries, fees, compensation in kind, commissions and similar
items; income derived from business; gains derived from dealings in property; interest;
rents; royalties; dividends; annuities; income from life insurance and endowment
contracts; all forms of retirement; pensions; income from discharge of indebtedness;
distributive share of partnership gross income; income in respect of a decedent; income
from an interest in an estate or trust; military retirement benefits; railroad employment
retirement benefits; social security benefits; temporary and permanent disability benefits;
worker's compensation; unemployment compensation; other entitlements to money or
lump sum awards, without regard to source, including lottery winnings; income tax
refunds; insurance compensation or settlements; awards or verdicts; and any form of
payment due to and collectable by an individual regardless of the source.
GENERAL INSTRUCTIONS
t. Employers may elect to deduct up to 2 % of the attachment amount for their costs. This
amount must not be deducted from the attachment. It must be paid from the employee's
net eamings after the income attachment deduction has been made.
2. If you choose to make payments via an electronic funds transfer, contact the Pa ScDU
Employer Customer Service at 1-877-676-9580.
Date of Order:
DRO: RJ Shadday
xc: defendant
Service Type M
JUDGE
Form EN-028
Worker 10 $IATT
December 9. 1999
Edw'Hd E. G~id0
....;, :0'". ";""~ ro- . Page 3 of3
~~_~jq(r"'~
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In thc Court of Commun l'lcas uf l'lIMllt:IU.ANI) County, Pcnnsylvania
nOMESTIC IU:I.ATIONS St:CTION
Dcfcndant Nmnc: LEONARD G. LANDER JR
Mcmhcr ID Numher: 9701100108
1'h'i1~l'IIIlIl': All rurn"IJCllldt'UH' 1111I\1 bu'Judt' tlu- ~kmhl'r III \'lIl11hu,
COMMONWEALTH OF PA
C/o PAYROLL OPERATIONS
PO BOX 8006
HARRISBURG PA 17105-8006-06
ORnER OF ATTACHI\H:NT OF INCOME
Plaintiff Name
MARVB'M'A L. I.JWDBR
MARVETTA L, LANDER
Finandalllreak Down of i\!ultillle Cases on Allachlllenl
I'ACSES nodel
Case Numher Numher
::?i'9~'i' 30410148. '8-57'. CIVIL
C(71v-~ 38010035. 00.03 S ",.
92.03 IBI-WEBK
319. 37 ~BI-WEEK
/
/
/
)
/
/
Al1,lchmenl Amount/l:n'{IUeIlCY
$
!
$
$
!
$
TInA!. ATI'ACII~IE~-r AM()L~T: $
411.40
To: COMMONWEALTH OF PA
Pursuant to the laws of the Commonwealth of Pennsylvania the income of
LEONARD G. LANDER JR , defendant obligor, SSN 176-62-1890
of:
38 WALNUT ST, CARLISLE, PA. 17013-3833-38
is hereby attached to the following extent.
You are directed to pay to the Pa State Collection and Disbursement Unit the sum of
$ 411. 40
from the income due the defendant obligor. The
per
BI-WEEK
attachment payment must be sent to the Pa State Collection and Disbursement Unit within
seven business days of the date the defendant obligor is paid.
CHECKS SHOULD BE MADE PAYABLE TO: PA SCDU
AND SENT TO:
Pennsylvania SCDU
P.O. Box 69112
Harrisburg,Pa 17106-9112
Service Type M
Form EN-028
Worker ID $ IATT
LEONARD G. LANDER JR
I'ACSES Memher Numher: 9701100108
PAYMENTS MUST INCLUDE TilE DEFENDANT'S NAME AND TilE PACSES
MEMBER ID OR SOCIAL SECURITY NUMBER IN ORDER TO IlE PROCESSED. DO
NOT SEND CASH BY MAIL.
This order of allachment for support is binding upon you until further notice and shall havc
priority over any attachment, execution. gamishmcnt or wage allachmentunder state or local
law except one rclating to a prior support order. You must commcnce the allachment of the
defendant obligor's income as soon as possible but no later than fourteen days from the date
of the issuancc of this Order of Attachment.
You are notified further that pursuant to law:
1. The defendant obligor has been notified that an order of attachment for support would
be issued.
2. Willful failure to comply with this order may result in (i) your being adjudged in contcmpt
of court and committed to jail or fined by the court; (ii) your being held liable for any
amount not withheld or withheld but not forwarded to the Domestic Relations Section; and
(iii) attachment of your funds or property.
3. The attachment of income or the possibility thereof as a basis. in whole or in part, for the
discharge of an employee or any disciplinary action against or demotion of an employee is
prohibited. Violation may result in (i) your being adjudged in contempt and committed to
jailor fined by the court and (ii) an action against you by the employee for damages.
4. If there are in your employment one or more additional employees whose incomes are
subject to an attachment of support. you may combine the attachment payments into a
single payment to the Pa SCDU and separately identify the portion attributable to each
obligor.
5. You must notify the Domestic Relations Section or the Pa SCDU when the defendant
obligor terminates employment and provide the Section with the employee's last known
address and the name and address of the new employer, if known.
Page 20f3
Form EN-028
Worker ID $IATT
Service Type M
LEONARD G. LANDER JR
PArSES MOlllher Numher: 9701100108
6. The maximum amount of thc attachmcnt shall not cxceed 55 % of thc cmployee's
net income which is within the limits sct in the Consumer Credit Protection Act, 15
U.S.C. *1673.
7. The term "income" as dclined by law includcs compcnsation for scrviccs. including, but
not limited to, wages, salaries. fees. compensation in kind. commissions and similar
items; income derived from business; gains derived from dealings in property; interest;
rents; royalties; dividends; annuities; income from life insurance and endowmem
contracts; all forms of retirement; pensions; income from dischargc of indebtedness;
distributive share of parUlership gross income; income in respect of a decedent; income
from an interest in an estate or trust; military retirement benefits; railroad employment
retirement benefits; social security benefits; temporary and permanent disability benefits;
worker's compensation; unemployment compensation; other entitlements to money or
lump sum awards, without regard to source, including lottery winnings; income tax
refunds; insurance compensation or settlements; awards or verdicts; and any form of
payment due to and collectable by an individual regardless of the source.
GENERAL INSTRUCTIONS
I. Employers may elect to deduct up to 2 % of the attachment amount for their costs. This
amount must not be deducted from the attachment. It must be paid from the employee's
net earnings after the income attachment deduction has been made.
2. If you choose to make payments via an electronic funds transfer, contact the Pa SeD U
Employer Customer Service at 1-877-676-9580.
Date of Order:
DRO: RJ Shadday
xc: defendant
Service Type M
'YTHE~
Edward E. Guido
JUDGE
Forlll EN-028
Worker ID $ IATT
January 14, 2000
kn.:r";~1 ~:~; ~ r,.-}~} ('.:~' Pag~ 3 of 3
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Master.
/
MARVETIA L. LANDER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
LEONARD G. LANDER, JR.,
DEFENDANT
98-5746 CIVIL TERM
ORDER OF COURT
AND NOW, this 25th day of February. 1999. following a hearing, interim
counsel fees are awarded to Marvetta L. Lander in the amount of $750 to defray fees
for the preparation of a bill of particulars. Further interim counsel fees are denied
without prejudice to plaintiff to seek an award of counsel fees before the Divorce
Edgar B. Bayley, J.
/
Mary A. Etter Dissinger, Esquire
For Plaintiff
Carol J. Lindsay, Esquire
For Defendant
:1 . .;J I., \'?
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In the COllrt of Cnllllllnn Plell~ of
ClJ~IIlERI.,\ND
COunl)', Penn~ylvanill
IImIlSII!: KILlll1l\S
1',0, no\ JlIl. (',IKI,ISI,C. ~.I. I1fIIJ
Phone: (717) 2~O.622S Fa." (717) 2~O.62~
:E~n~.'\R'! 5, :'')JJ
Plaimiff Name: MARVE'l"I'A L, LANDER
Dcfendant Name: LEONARD G. LANDER JR
Docket Number: 00803 5 1998
PACSES Case Numbcr: 380100354
Other S,ate ID Number; ::r. 79'1::'-
Plt'a.~c oOle: AU corrC'lpondeucl' mllU include Ibe I',\CSES Ca.~e :\'umhrr.
In clime and EXDense Statement
THIS FORM ~UST BE FILLED OUT
(If you are self-employed or if you arc salaried by a business of which you are owner in whole or pan, you must
also fill nut the Supplememallncome Statement which appears on the last page of this income and expense
statement.)
INCOME STATEMENT OF L E:.ONAK.O (;.. J....,q'JOFJ'-. Uif.
( verify that the statements made in this Income and E<pellse Statement are true and Correct. I understand that
false StJIlements herein are subject to the criminal penalties nf 18 Pa. C.S. ~ 4904. relatiog to unsworn
falsification to authorities.
.,/~? Ic<-
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Plaintiff or Defendant
Dale
INCOME:
Employer
PA
'>TriTe POLlc..",-
Address /53a COMMn"-to; A i/.s:, ('"r9~L/SLo. ""'''I /701:3
Type of Work 'pOLI(.; OFf/c..:;/<.
Payroll No.
Gross Pay per Pay Period $ dJiJl. '-14 Pay Period (wkly., bi-wkly.. etc.) /Ii '.'.-KL.Y
Itentized Payroll Deductions:
Federal Withholding
$ZJQ.;-' Social Security
Od.er Deductions (specify)
~:'''''A. il.I..:}/<.; Fcm
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$9tf,t,.''1 Savings Bonds $
$ Health Insurance $
$9 ""7 SLI"o/'....II\.T -(,.1-1/1.'/) Sz,N, $'
,,-,
State locome Tax
$.).2......?, Retirement
Credit Union
$ Life Insurance
Net Pay per Pay Period $ -f/. 2.3j'. ,-1
Service Type M
Form IN-008
Worker lD 21206
, '.
IU..\H11t: JIlU E:<pcIIW SIJIl:lIIc.:1Il l'i\CSES Ca,e Su",ner 380100lSl
OTHER (Fill illl\ppmpriale Colullnll
(SemlE
WEEK :\IOSTII YEAR
Interes( S S S
Diviu.llus
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AnnuilY
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RentS
Royahies
Exp.ns. Accoum
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Cumpensation
Workmen's
Cumpensalion
IRS Refunu
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TOTAL $ $ $
TOTAI.INCOIHE $
(Fill in Appropriale Culumn)
EXPENSES WEEK MONTH YEAR
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$
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$ Co </LIB, Od
Maintenance
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Page 2 of 6
Fonn IN-OOa
Worker ID 21206
Servic. Type M
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IIII.IIIIU: .1111.1 Ex.pclI.,C SlalL'lIICIII
I',\CSES Ca,e Numher 38010035~
IFill ill Appropriale e"luIIIIII
EXPENSES I
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Personal Propeny '''It.L. uL
Income
Insurance
Homeowners $ $ $ :J la. va
Automobile J ., C. f'" I uuO, 4,
Life
Accident
Health -
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Automobile
Payments $ $ .,",.,n<., $ ., Q32.. 72-
Fuel 5"Q .=U '2..::>~, un ? u oc). ;) ()
Repairs j ooo.:7V
Medical
Doctor $ $ $
D~ntis[
Onhlldontist
Pagd of 6
Form IN-ODS
Worker 10 21206
Service Type M
11IL:IIlIIC anLl E"'f1CIl'lC StJIClIICIU
PACSES Ca," :'oiulIIher 380100354
EXPENSES
I Fill ill "Jlprnprial" CoJu1II1II
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Llcvil.:csJ
Educatioll
Privale Schnnl S S ,
,
Parnchial Schnnl
ClllI<ge
Rdigiolls
r'A''''''- 10. ...:>0 .j /2 o. <~CJ
Personal
Clothing S S S IDOO :Jil
Foo~ 5'0. oJ" 2.DO ,:)u 2. Y.:J<J...:J (J
Barber/Hair~resser
Cre~h Payments: C.c..c...5.
Cre~it Car~
Charge Account ')-7G.oQ ~ (,<117 :;}"
M<mb<rships
Loans
Crew I Union S S S
A <:_(u(../,q roI /5'>-. u iJ /6'-'3 1(.
Mlscellaneons
HllusehllJ~ Help $ $ $
Chil~ Care /Oil-<>)
Pap<rs/Bllllks/Magazine
Eluc:rtainmem d/..:Ju JU IJ.::>u..:JU
Pay TV ~? '-/'r 401. af'
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Service Type M
Pag< 411f6
Form IN-OOB
Work<r lD 21206
,
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P.\C:LS C.a'...: \Ulllt~~'r :~".........j.~.j
EXPENSES
trnn,InllP11\
WEEK
I Fill ill Approprialc Columll!
YEAR
Gifts
Legal Fees
Charilahlc COlllrihutiollS
Olher Child Support
Alimony Paymellls
/31 ,..Iut..........
.l' 0
Other
$
$
- ,,) rJ
TOT AI. EXPENSES
$
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$
PROPERTY DESCRIPTION
OWNED
Checking Accounts p 6('U
Savings Accounts r5u.J
Credit Union ~ sS'
Stocks/Bonlls --
Real Estate -
Other a~ .,.IJ,,<.JIr'l LrIrAJt.y
!?J~' ,:...:11\1'/ _ ')".J
TOTAL
INSURANCE
COMPANY
8,-'.1"; G/!.O':> I
Hospital
Blue Cross
Other
Mellical
Blue Shield
Other
* H _ Husband W - Wife C - Combined J - Joint
8L<1O 5Nt&
Page 5 of 6
Service Type M
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8
MARVETTA L, LANDER
Plillntiff
IN TilE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vo.
,
.11 LEONAlW G, LANDER, JR.
Defendilnt
I
I
I
C I V I L ACT !ON
NO. 9H-S74G
It1 DIVORCE
PETITION FO&_fl~E~_t~L-B~LIEF
AND NOW comes Marvettil Lilnder by i1nd through her attorneys,
DISSINGER & DISSINGER, and respectfully requests this honorable
court for special relief seeking an award of interim counsel fees,
expenses and costs and avers as follows:
1. Petitioner is Marvetta L. Lander, residing at 595 Geneva
Drive, Unit 11, Mechanicsburg, Cumberland County, Pennsylvania,
2. Respondent is Leonard G, Lander, Jr., residing at 125
Steelstown Road, Newville, Cumberland County, Pennsylvania,
3, Plaintiff, Petitioner herein, has filed the complaint
alleging both fault and no fault grounds, including a count for
indignities under 3301(a) (6) of the Divorce Code.
4. The Defendant, Respondent herein filed a Rule for a Bill
of Particulars, said Rule is attached as Exhibit "A".
5. Petitioner believes the aforementioned Request for Bill
of Particulars are unnecessary and designed to harass her and her
counsel and increase her attorney's fees.
6. The Plaintiff, Petitioner herein, has been put to
tremendous expense defending a frivolous criminal complaint filed
by Defendant, who is employed by the Pennsylvania State Police,
solely for purposes of attrition and harassment.
7. Because of these actions by Respondent, Petitioner has
incurred additional attorneys' fees.
II
II
'I
i
I
I
I
I
I
I
I 8. The expense to which Petitioner has been put was
I unnecessary,
I
WHEREFORE, Petitioner respectfully requests the Honorable
Court to award her interim counsel fees in the amount of not less
than $3,000,00.
Respectfully submitted,
DISSINGER & DISSINGER
BY: '--?fi c,,^,,( {~ l1:ft:""A
Mary A. Etter Dissinger, Esquire
Supreme Court 1D # 27736
28 North 32nd street
Camp Hill, PA 17011
717-975-2840
Attorney for Plaintiff
I:
....w.__. -_ - .~_.__._..-..~.~...._~_.._.-
MARVETTA L. LANDER',
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 98 - 5968 CIVIL TERM
vs,
LEONARD G. LANDER, JR.,
Defendant
IN DIVORCE
PRAECIPE FOR A RULE FOR
A BILL OF PARTICULARS
TO THE PROTHONOTARY:
Please enter a Rule upon the Marvella L, Lander to file a Bill of Particulars pursuant to
Pennsylvania Rule of Civil Procedures 1920,21.
FLOWER, MORGENTHAL FLOWER & LINDSAY, P,C.
Attorneys for Plaintiff
{J(~
Caro J. Lindsay
',/' 10 # 4693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
Date:
{)( f L- 4.. I (t/tj,f.('
I
I.'WOJlJlICIiS
HAIIHH, SIIU(<'I", l"I.()WI~n & 1.INnHAY
J,\~IESI) F1.(I\\'I.:R
JOliN E SLlKE
ROUERTC S.\IDIS
(iEOFFIlEY S SIIU+
J;\~IES I> "U )\\'I':R.)R
C.\ROI.).IJNDS.\Y
JOIINNAJ DEILY
KARL L. lJmEn()II~1
JOSEl'III~ IIITCIII~GS
'1110~L\S I~, Fl.OWER
E. Robert Elicker, II. Esquire
9 North Hanover Street
Carlisle, PA 17013
Dear Mr. Elicker:
A PROfBSSIONAL CORPORATION
26 WEST HIGH STRBlrr
CARI.ISI.Il, PENNSYLVANIA 170U
T('\('l'hOlI(': (717) 2.0 (,:!;!2
F,I(5imil"c (717):!H C,.JKC/
E.M.\II; Jllllnlt.\(ll1.dll.i......(lJlll
(lI'I,()Ur-.;SI.:I.
.\I,BEIt"!'11 ~1.\SI..\Sl)
WH.."'T SllOttE OFPICE
.:!llnM.uutSUttt
CUllp 1Iill.1):\ 17011
TC'k-phulX' (717) 7.\7.Hns
rAC\Uluk. (717) 737.)4l)7
KEPL Y TO CARUSlli
August B. 2000
RE: lander v. lander
No, 98. 5766 Civil
Enclosed please find the certification regarding discovery in the captioned action.
CJlJtjb
Fndoc;llrQ
cc: Leonard Lander
Mary A. Etter Dissinger, Esquire
Very truly yours.
SAlOIS, SHUFF, FLOWER & LINDSAY. P.C.
Ct2/t (If-/! ~_r;dJ<<;1
Carol J. LindstJ . 'J
ff
I.AWOITIlTS
foLOWER, MOR( il:NTIIAL, l'1.0\VI'.R & u"ns'\ y
\1'IHIII "111'0\111)1<:1'1111\1111',
II L\ST 111(;11 STI<FI:I'
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J^MJ~~ I) 11,('I\\,U:'
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lil71 ~U,:;:;I.\
lAX \7171 ~I.\.l;:;h'
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11I.'\H"."I\,\.\\t:I~
.\h'Hl;r:--:nl.\I..,nl1WU,
lI'I~.;, I'I"~I
Janu:lry 28. 1')')1)
The Honorable Edgar B. Bayley
One Courthouse Square
Carlisle. PA 17013
RE: LANDER vs LANDER
No. 98-5746
Dear Judge Bayley:
This letter is in response to the Petition for Interim Counsel Fees. Expenses and
Costs filed by Mary Dissinger. Esquire on behalf of Marvetta L. Lander. the Plaintiff in
this divorce case. Ms. Dissinger had filed previously. on December 4.1998. a Petition
for Special Relief also seeking Interim Counsel Fees, Expenses and Costs. This
Petition was dismissed by your Order of December 9. 1998. If this Court issues a Rule
upon Mr. Lander to show cause. we will be happy to show cause why the Petition
should be dismissed. It is the purpose of this letter to point out to the Court that relief
requested has already been denied and that there have been no change in
circumstances since the December 4th Petition was filed to justify a revisitation of this
issue. nor does Ms. Dissinger aver that there has been. The law. furthermore, does not
support the basis for Ms. Dissinger's request for counsel fees and costs. She avers the
need for costs for a support action and a custody action as well as for a defense in a
criminal action. Counsel fees are not awarded in those matters. I would urge the Court
to once again dismiss this Petition which will undoubtedly incur additional attorney's
fees and costs. Thank you very much for your assistance.
Very truly yours.
CJL:ljj
cc. Mr, Leonard Lander
,../ ~
Oct-16-98
Oct-19-98
Sep-29-98
Oct-07-98
Oct-19-98
Oct-21-98
Oct-22-98
Arranged service on Defendant
Telephone call to client
Telephone call to client
Travel to/from Carlisle; filed complaint
Telephone call from client; travel to/from
Chambersburg; appearance at conference with PSP
consultation with client
Draft memo to file (NC)
Total Attorney Services
1,425.00
Secretarial Services:
Sep-30-98
Oct-05-98
Oct-14-98
Oct-19-98
Telephone call to client (NC)
Conform divorce complaint
Telephone call to Cumberland county Courthouse (NC)
Telephone call to Gilroy (NC)
Total Secretarial Services
16.00
Word processing Services:
Sep-29-98
Sep-30-98
Oct-15-98
Oct-19-98
Word Processing I&A instruction letter; word
processing divorce complaint print blank I&A and
I&E forms
Word Processing revisions to divorce complaint
Word Processing letter to client
Word processing affidavit of mailing
Total Word processing Services
56.00
Oct-15-98
Paralegal Services:
Draft letter to client
Oct-19-98
Draft affidavit of mailing
25.00
Total Fees
Total Paralegal services
$1,522.00
-
Costs Advanced:
Sep-29-98
Photo copies of I&A
instruction letter
$0,20
Oct-05-98
Ret.ainer
Photo copies divorce complaint
$3.60
$0.20
$0.20
Oct-15-98
Photo copies letter to client
Photo Copies affidavit of
mailing
Photo Copies letter to Gilroy
$0,20
oct-19-9a
Total Costs Advanced
$4.40
Total Fees and Disbursements
$1,526.40
Trust Summary:
Oct 05/1998 Trust Funds received
Oct 06/1998 Trust Funds disbursed
Oct 06/1998 Trust Funds disbursed
Trust Account Balance
$275.00
$245.50
$5,98
$23.52
Please
November 21, 1998.
after that date,
remit the outstanding balance due on or before
Interest will be charged on any unpaid balance
Very truly yours,
Mary A. Dissinger
MAD:spa
Nov-02-98
Prepare for Domestic Relations
Conference (NC)
Nov-04-98
Telephone call to client (f> calls) (tiC)
Nov-05-98
Telephone call to client
Telephone call to client;
study Husband's wage data and compute
Nov-06-98
Nov-09-98
Telephone call from client re:badcheck
Telephone call to client
Nov-11-98
Draft letter to client;
telephone call to client; compute wages
Telephone call to Captain
Fisher (NA/NC/LM)
Nov-12-98
Telephone call to client
Telephone call to Carey
study/Review agreement from
Carey; Telephone call to Carey
Telephone call to Fisher
Nov-13-98
Consultation with client and.
Draft Bill of Particulars
Nov-16-98
Travel Filed Bill of Particulars
Draft revisions to Bill of Particulars
Nov-20-98
Telephone call to client (NA/NC)
Nov-03-98
study/Review letter from
Lindsay; prepare response to
Rule for Bills of Particulars
and .prepare Rule of Attorney's Fees
Nov-04-98
Travel to/from Carlisle to
file affidavit of mailing
study/Review Bill of
particulars; review forms
Appearance at support Conference
Nov-06-98
Consultation with Mary (HC)
Nov-IO-98
Nov-12-98
study/Review information from
Private investigator; Draft
letter to client; Draft rough
draft of petition for counsel fees
Draft and word processed
Motion for Interim Counsel Fees
Total Attorney services
Oct-22-98
Secretarial services:
Oct-23-98
Oct-26-98
Telephone call to client (NA/NC/LM)
Telephone call to client (NA/NC/LM)
Telephone call to client (NA/NC/LM)
Total secretarial Services
Word processing services:
Oct-27-98
Nov-lO-98
Nov-11-98
Nov-13-98
Nov-16-98
Word processing letter to client
Word processing letter to client
Word processing rough draft of petition
Word processing letter to client
Word Processing Bill of Particulars
Word Processing Bill of Particulars
Word Processing revisions to
Bill of Particulars
2,347.50
0.00
~ ..
Miscellaneous conform Bill of Particulars
Miscellaneous Conform Pet, for
Special Relief
Total Fees
Total Word processing services
Oct-27-98
Costs Advanced:
Oct-28-98
Photo Copies letter to client
Fax from Client
188.00
$2,535.50
$0.20
$2.00
~ i~~in!ler
&
1Bissinget
%lttornrps S!l:t J[alll
MARV A. ETTER DISSINGER
WILLIAM CHESTER DISSINGER
STEPHEN OEOllOE tiElD
December 22, 1998
C.mp Hill Otlic:,~
28 tI. Thi/1y.S,cond SUII'
C.mp nil. P,nlllylll,ni. 17011
717975-1640
FAX 717 97&-3924
Muylyill. ~Ille.:
400 South Slate fload
P.larYSllille, f'tHlIlsylll"ni. 170,3
717 957-3474
FAX 717 957.2310
MATTER # 3-98-566
INVOICE # 7959
Marvetta L. Lander
595 Geneva Drive, unit 11
Mechanicsburg PA 17055
Dear Ms. Lander:
Previous Balance
Payment on Account
Current Charges
outstanding Balance Due
-----------------------
-----------------------
Attorney Services:
Nov-24-98
Telephone call to client
Dec-08-98
Telephone call from Judge
Oler's office (NC)
:..
Telephone call to client (NA/NC)
Telephone call from client
Dec-I0-98
Telephone call from Lindsay
Prepare for custody Conference
7elephone call to client (NA/NC/LM)
Dec-1l-98
Appearance at custody Conference
$2,547.30
$0,00
$838.70
$3,386.00
-------------
-------------
Total Attorney Services
Secretarial Services:
Dec-22-98 Telephone call to DRO (NC)
Jan-11-99 Telephone call to Atty Lindsay
(NC)
Jan-19-99 Telephone call to client (NC)
Total secretarial Services
Word processing Services:
Jan-15-99
Word processing letter to
client
Word Processing Petition for
Interim Counsel Fees
Word Processing letter to
client
Jan-18-99
Word processing final
revisions to Pet, for cousnel Fees
Total Word processing services
Interest:
Jan-23-99
Interest charged on unpaid
balance through January 21, 1999
Total Interest
Total Fees
Costs Advanced:
Jan-11-99
Fax from Lindsay (NC-1)
Photo copies letter to client
Photo copies letter to client
Photo copies Pet. for Counsel
Fees
Jan-15-99
Jan-18-99
Total Costs Advanced
Total Fees and Disbursements
345.00
0.00
72.00
50.79
50.79
$467.79
$0.00
$0.10
$0.30
$1. 80
$2.20
$469.99
- .
11\ issinger
8::
miSsinger
~ttot'nr!,~ $1H l.nw
; PErlrlONER'S
EXHIBlr
MAllY A. [lUll PISS1NOEIl
WIlliAM cursun DISSINOUI
SHPtlEN OEORGE HElD
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lAX 11"1 9~7 ]:I\(,
r i If> ~':.:-:JC()
Marvetta L. Lander
125 Steelstown Road
Newville, PA 17~41
Dear Ms. Lander:
You have ilstaG our firm to rcpres0nt 'lUll ill ,J llivr.rce,
support, cUf>tody, equitabl'3 distribution, ul imony, dlimony l'l;~nc1entl~
lite, counsel fees, e>:penses and costs action. 'Tjli:::.~ Jelt!!,.. ~;~ts
forth the agreement conce:r:ning au::" representation ul YOll and shall
be effectiv:2 upon receipt of t.he retulner f(:o. \.!e C;ll1flor. underta}:{>
to do any t'Jot-}: on your case lllltll '..J8 receive t11f..~ enclot;ec1 i.lCJrcpment
signed by you and a ret;\iner in the ill,lount of $1,:;0\).00. Tile
retC'liner is a mii,imum fee and is not refundable. The r.etainer
requested is only to begin YO....lr Ci,f'P, \'!Q arE! lil"L.-:d.J10 t.O u.lll you
specifically :-,.ow much ~:'GlJr c()se "'Jill cost t:"Jn:"Ollgl1 iLS conclusion.
Therefore, it 1.5 nec(-:!ssary to represent. YO:l on ,li1 ;i(,lIrlY rat.e
basis. In the o",:.;:nt t.l1rlt ',{Odr '::-~lvorcc, Sll!)t":,(~,, cu:-::t".(',dj', ':'_ql1ita\...l(~
distributi.on,
alimony,
:llim011Y p1Jf,d211t0
1 l t(l ,
,::ltl ns,:, ~
toe;:'"
expenses ".nd costs ilctlon is riot c,)mF'let~d t..:itiiiil tl""~ loil1li (,s or
this retainer fee, \'Ie. \nill (1[J~ly the ~.t~~_diilP.l: ll~';.:' Lv tli.-! l,iod:
performed and bi.L:' yul1 suuseq:J12:ltJy 011 lln lVAlr:'}y bd:'::i.:~,. r~ti:-~ t.o ttl<:
naturp. of "Chis matt.er ..".Jllcl -the imposs.i..h.i.!.ity or uetecmirlirlt! '...'hilt
course the lnatte::l' maY tar:C:, ....Jf.~ dre llnabl(: to ,.'f".r.'....b:Li'-~h ;'i t:':-It. tee:
for oue prof8ssjcna.l servjce~. OUt. j)j lliny~:; at:1..! bt:l!'-~ed (lr~ t.he--
preser:t hourl~.. r"2:tes :"";et tort:, .in Lh0 "'1'"C.':.;,,(~11(!':: 11:0'" ;~(:~ill?'ll1.I'''!, uur
hourly rilten ilre :Hjjl1:.~t(l'.:1 t'ver'V .JilIlU.Il"Y. \.J1\I,'1"1 till' lIpur-ly "dt(.:~ iI'""
adjusced you wili be not.it i.',.1.
Cants al~C our out: -(II -P()C~:f't (~}:r'~Il~;('~;, ~aIL'11 .\:', I i I i IHI t (.(>n I
proccGs ncrver tC'O!i, tr.'Il:~("riptfi, pl1otO('()pi(1:;, ledl,! di:;tdIlL~t'
telephone calls, travel mi l{'aCJp, iIlVt.}~;LilJdt0r:'., .lPI)l'di::('r:~, dlFI
accountants. You 'vI i 11 be r-equ i r-cel tu depo!i i t thp ~all~l 0 t ~:;/ 'fl_). un on
account of costs. Cost~i will also be itemized dnd tJJlled on d
periodic basis,
costs and expect.
bi 11.
We will bill you monthly
payment wit.bin t.hirty (3D)
for lC'Cjdl ~~l'r"vice~-i ilnd
c1ay:".ot the Il.ltp of the
Our statements ure CjenpJ"<:-\ 11 y prem i sed upon tilt. dr:lollnt of
professional time e>:pended by the attorney;; ;lIld ,;talt in OU'" off ice
for such services as conferences, teleptlorlC corlrerollc0~;, f"cse~rcll,
court appearances, travel, ilrld otller" misccllallcollS legi\L ~;er'vices.
In addition, other considerations may enter into thp ficttincJ of a.
fee, such as: the novelty and difficulty of the is;;ues involved;
the result achieved; the amount in dispute; the Ill-:c(~s~-;ity of a
specialized sl;ill requisite to perfoH' the leqill service properly;
the likelihood that the acceptilnce of il particulilr employment will
preclude other employment by the attorney; time limitations imposed
by the client or by the circumstances; the nature ancl lenqth of the
professional relationship vlith the cl iellt; the area of lill'l
involved; and the interruption of other work in proqress.
It is impossible to determine ill advance tile ~mollrlt of time
that will be needed to complete your case. We will keep you fully
informed of conferences, telephone c~lls, dl4afting at: documents,
research, court time and Ilecessary travel time.
We reserve the riqht to terminate our attorneY-Client
relationship for non-payment of fees or costs. We expect you to
keep current with our billings. If your retainer has been exhausted
and there is still considerable l'lor}', to be done on your case, YOll
may be asked to replenish your retainer and costs before our legal
Hork continues.
.
We will y'~(>p YOll inlnr.nt:r.l olD to tht. prcq"f!~.~~ at your t:d~~f'. ~.;('
will send you COpi(~5 (iJ all pdIH:!rr; comin'J i:~ dnd lJOI:HI out 01 CllU'
offices, includlrlq C01T('~;pol\d('ncc, ple"HJinCJ~; "nd othl'J' d(J'.'U!'.lt.tlt:~.
If we are un('.vailable .....'h0n YOll telc!;hone, you:" Cd 11 vIi 11 )Jp
returned \oiith rCilsor~.1blo p14ornptnesL;. 'l'hC'rc 'vIi II 1.'l' t imf':; '.'Jlu'f1 .,./(.
will be in court or ilt meelln<jt-i or in conlel"l'ncr', It:liit~h "..i 11
preclude U5 from l"eturninq yc.t:r Gill \ as quid:lv i:S you ''licJht I if:".
but we shilll do our bc.,t to ,-et:urn your tclcpholw cill I"~ ,,,; ,;oon as
we can. At such times, plcllcc feel confident to taU: ...l1th ollr
secretaries. It Y0U arc p~lssing on information, t.hey Clll1 deliver it
to us without the necessity of YO!.lr wi:itin'J to hilve us return the
call. If you hilV8 a questi':ltl that !"eql1i!"e~j an ilnS'llt!r IroJ":! 1I<'~, it is
far easier for them t.o auta ill the bCtC~:grollnd f t'O!:'! YOll, lJ~~ i r1CJ the
matter to our attention \.!hcn \.:c are free, and then lldVt: ~l r(!~~plJnse
for you. If it is necessilry for you to speak with UR dir0~tiv, we
will attempt to returrl your call as soon as possilJlc.
Every effort will be ",,-,de to expedite YOLl'- case prol\iptly and
efficiently according to t:he highest leqill ilnd etllical standards.
Please acknowledge ::-e:;eipt of the enclosed dqreemellt ,Hid your
acceptance of its terms by signing the enclosed copy dnd returninq
it to us so that we will have il mutual memorandum of our
understanding. The other copy we have enclosed is for you to keep
for your records. \'le suggest th~lt you }:eep your copy of the
engagement letter in the folder we have provided to you. along with
any future correspondence from this office. In addition. if you
ever have questions or comments for me in the future, YOLl Cdn write
them down on a piece of paper and slip that into the folder for
reference the next time you correspond with or cilll our office.
Respectfully.
DISSINGER & DISSINGER
1J1cvLfI..-l . c~ .:Lu::w/il~r"-
(I tJ.ES(I
Mary A. Etter Dissinqer
Accepted this
~'-/!J
~.
day of OrJ:O/'lffl . 1993
~1[2012fj",_t~o.f.QL:lCb./)
Mar~etta L. Lilnder
,
.~,,~
~~~
OFFICE OF DIVORCE MASTER
CUMBHlL^NlJ COt IN I Y
COURT or COMMON I'll N;
g Nor1tl t lallover Sth1!!1
Call1;,ll!, PA 1701:1
(7l?) ~!.tO {i~}:l~
E. Robert Elicker, II
Divorce Masler
West Shore
0970371 LxI 6535
Traci Jo Colyer
Ollic9 Manager/Reportor
August 23. 20(J(J
Marvetta L Lander
595 Gcneva Drivc. Unit I I
Mechanicsburg, PA 17055
('arol J Lindsay
Attorncy at Law
SAlOIS. SIIUFF. FLOWER & LINDSAY
26 Westlligh Strcct
Carli sic. PAl 70 IJ
RE: Marvella L Landcr vs. Lconard G. Landcr. Jr.
No 98 - 5746 Civil
In Divorce
Dear Ms. Landcr and Ms. Lindsay:
I havc receivcd thc ccrtitlcation from Ms Lindsay indicating that discovcry is
complete. Ms. Landcr indicates that shc is in the proccss of obtaining ncw counsel.
Attorncy Dissingcr was dismissed as counscl by order of Court of April 19,2000.
A divorce complaint was tiled on Octobcr 7. 1998. raising grounds for divorce of
irretrievable breakdown of the marriage and indignities. The complaint also raised
economic claims of cquitablc distribution. alimony. alimony pcndcntc lite, and counsel
fecs and expenses.
Based on the certification of attorney Lindsay and undcrstanding that Ms. Lander
is in the process of getting counscl, I am going to procccd with thc case but will give
some additional time for filing of pretrial statements deviating from our customary
schedule.
In accordance with P.R.C.P. 1920J3(b) I am directing Ms. Lander and attorney
Lindsay to cach me a pretrial statcmcnt on or bcforc Monday. October 2, 2000. Upon
receipt of the pretrial statements. I will immediately schedule a pre-hearing conference
J<Hl 1'l!/GOl
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2:S..:4 l'hll,,' :,111 .....,tti , : ' ) .. : ~ : ,.;.
A", If,/.1000 I.,r....yl\/ : 1: t.CO HI:; 1. !" ,'" ."
2 j ~; 0 Ii ! rh',,:.!) '_>I:l with (:li!)l,t" . _'. t 1 ~: .: r ,'" '" l " ~:
dit!1:'_ .1:.'1 ,lllYll:1 ';"r.ci!:.I'l',l.,
Auq l~!;OOO 1.1wYI:r: t.l ').JO HI:; ;( 1 !~. CD ,. .. ,1'.:,'
2~('21b 1'010 I;h 0 r. l~ ,;;d1:l '....lth d il-!::~.
Au, 291200'J Ll'....yl'r: 14 0..10 ill:; ;( I 7~. OJ I ~ !' ;'.",':;
255S03 ~h\!n!: c.ill ....ith dle:lt.
30/2000 !.rl'....y!!I: I' 1.00 flr:1 ;( lI'l.(]C :r'J.'::',) 1,';,11
75flOl6 [)/iJ!1 ^qrel::T:',nt ('f :)iLl", ! '~l I '!: :; t,)
~r:l. Low:.:,,::J, c')\,n~el dn:! bWI'J:::.
Sop 1\/1000 f\l!.ur;':i c" UiV(l!CE n5.11 i' ~':-ll
"
/,8484 FEE:: t;hi'. ~G
Oel 2/200'J l,'lwyef: 1.1 1.5C Ht:1 ;( 1,':). ~G /i,I.':1 ..H.l'j
26378,1 l'ro!J.Ht' plI.tri.ll :i t iJ ~ ell,!!:~ !. , I, r ~ ' ) : . I . ':,1;; II: -
with cl i(lntj ,:'JI.fHrntiCe ..... j ~ L V;l ; ~: IJ,f::
and Il!'Ii:w aiJteer:i'mt. "1 ",.11 ,~ .
Oct 11/2000 flILLn:G eN I~VOIC~: 2Jl)Hti J.cr) 13':i~L
262902
No, 1/2000 J.i1WYI!t': 14 0.20 Hr.'l ;( P~.DC l~.QC t-p.:J
26636" Phonn call with diUllt.
3/2000 Lawyer: 14 \.20 Ilr" ;( !'I~. GO 2iD.CO 1.:J.:!
267802 Pbonll c.ll1 with cl lent and CPD, dr,J!t
rulea:w, ~t:one cull with C ou n~: I! 1,
letter to couns(ll.
Nay 6/2000 BILLiNG ON INVOICE 14H9 0. .:\) (:,:,:n f'NU.
266663 FEES 262.50
15/1000 La...yer: 14 7..00 Hrs ;( PS.OO ,';J.SG J.p.l!
268118 Phone call .....ith USDA, client, (;:),111:;(:: 25v
and Mr.'l. Lander. COnfllrl!nC" ,....ith I~:;, ,
Landur.
-Nov 21/1000 La',.;yer: I' 0.40 Hrs ;( 175.00 70.00 2nO
270136 Phone call with client, lutter to U;';Di\
No, 28/1000 Lal.,)'cr: 14 0.40 H" ;( 115.00 70.00 2HO
269512 Phone call with counsel, Or.
Shienvold'::l office, court.
No, 29/1000 Lawyer: 14 0.30 Ilr:; ;( 115.00 57..:0 2PO
269891 Phone call with cl iont, cour.:;el.
Cec </2000 BILLWG ON INVOICf. 2410 0.00 2.r10
210.169 FEES 13'1.50
Oec H2000 Lawyer: 14 0.50 firs ;( 175.00 81.50 25356
270722 Phone call with Dr. Sheinvc>ld and
client.
Cec 19/2000 La...yer: 1< 0.10 Hrs ;( 175.00 122.50 25356
272976 Prepare for prehearinq conference.
Cec 20/2000 Lawyer: 14 1.\0 Hrs X 115.00 261.50 25356
273179 Attend conference wi th divorce ~il:;ter.
Jan 3/2001 Lal.,)'er: 11, 1.40 Ilrs ;( 175.00 245.00
21<692 Phone call with S<111y Worst and c! ient,
research on non VO.'ltea ponsi0rls,
Jan 3/2001 La...yer: 1< 0.30 Hrs ;( 115.00 52.50
216184 Phone call with Harry Leister.
Jan 8/2001 Lawyer: H 0.60 Hr:; ;( 1'15.00 105.GO
275115 PhotlC call with Jeff Shat;',:, cl ient,
court and Hal'ry Leister.
Jan 9/2001 BILLING Oil INVOICE 25356 0.00 25356
21<930 fU.:S 112.50
Jon 9/2001 Stoven W, Barrell 1050) 7.50.CO
275l!16 Appraisal; Invoice ~ 00-066 'I
Jilll 9/2001 Lawyer: 1" 2.10 Hrs ;( 115.00 36'1.50
215233 Conference with Sally Worst, pho:\l! cilll
wlth conciliator.
f
AUG 2 4. 200atl )
MARVETrA I.. LANDER.
Plaintiff
IN TilE COlJRT OF COMMON PLEAS OF
l'l iMIlERLAND COlJNTY.PENNSYLV ANIA
v
l'lVIL A('TlON - LA W
LEONARD G. LANDER..!Roo
Dclendant
NO, 98-5746 ('IVIL
IN ClJSTODY
eOlIRT ORI>EI{
AND NOW, this _~ 'llJday of August, 2000. upon considcration of the attachcd Custody
Conciliation Rcport. it is ordcrcd and dircctcd as l'ollows:
I. A hc.lring is schcdulcd in COlll1room No.2 of thc Cumbcrland Cuunty Courthousc
on the 7t/1 day of Dcccmbcr. 2000. at Li.., . II .M. at which time
tcstimony will bc takcn in thc above case.
2. The partics shall Im\'c anothcr Custody Conciliation Conlercncc via a telephone
confercnce call with thc Custody Conciliator on Friday. No\'cmbcr 10, 2000 at 8:30
a.m. Aller this Conciliation. thc Conciliator shall rccommcnd a furthcr ordcr to thc
Court with rcspcct to the partics rcquircmcnts to liIc prc-hcaring memorandums and
any othcr issucs the Conciliator fcels nccds to bc addresscd,
3. Thc partics shall submit themselvcs and thc minor child and any significant othcrs
that an cvaluator dccms appropriate to a custody cvaluation to be performcd by Dr.
Arnold Shein\'old. Costs of this cvaluation shall be split bctwcen the partics with thc
Fathcr paying 65% and thc Mothcr paying 35%. It is dircctcd that thc custody
cvaluation bc complcte with a written report providcd to the partics in advancc of the
Custody Conciliation Confcrence schcduled abovc.
4. Pcnding furthcr Ordcr of this Court. this Court's prior Ordcr of Dccembcr 16, 1998
shall rcmain in effcct subject to the following modifications:
A. Fathcr's pcriods of tcmporary custody shall be on three out of four
weckends from Friday cvening until Sunday evening at 8:00 p.m.
Two of thcsc wcekcnds shall be thc weekends thc Mother is
working. Thc third weckcnd shall bc as agreed upon by the parties
with thc partics to work this out at least three (3) days in advance.
B. For purposes of cxchangc of custody, the Father shall be required to
handle all transportation on two out of the threc weekends. On the
third wcckcnd, thc Mothcr shall bc required to share the
transportation with cither handling all transportation on Friday or
Sunday or thc parties meeting at a mutually agreeable halfway point
bctween the Mothcr's home in Mechanicsburg and the Father's
current home in Greensburg.
".. <- ..",.
The ahow OrJcr as it relalcs (0 transportalion shall not prc:iudice eilhcr party from
laking a contrary position on transportation ohligations oncc thc Court aJJresscs thc
mcrits as to \\hdhcr or notthc Mothcr will hc allowcd to relocatc to KanStlS with thc
child anJ Fathcr's pctilion to haw primary custoJy translcrreJ to him so he can
relocatc thc chilJ 10 <irccnshurg.
5.
cc:
Jeflrcy S. Shank, Esquirc
Carol J. Lindsay, Esquire
Y7
I~Y TilE COl~~ I
\'/J'iC wv1
Edgar B. Bayley ~
J. .~
( ~&
VL\'~ ~
MARVETJ'A L. LANDER,
Plaintill.
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LA W
I.EONARD G, LANDER. JR..
Dcfcndant
NO. 98 - 5746 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this -1J!... day of January, 2001, upon considemtion of thc attachcd Custody
Conciliation Rcport, it is ordercd and dircctcd as follows:
1. The Prior Ordcr of Court scheduling a hearing in the above matter for March 21,
2001 at 8:45 a.m. shall rcmain in effect. Counsel for thc parties shall filc with the
Court and opposing counsel a memorandum setting forth the history of custody in
this casc, thc issues currcntly bcfore the Court, a list of witnesses who will be called
to testifY and a summary of thc anticipated testimony of each witness. This
memorandum shall be filed at least five (5) days prior to the mentioned hearing date.
2. In the event counsel for the parties feel that another Conciliation Conference in
advance of the March 21st hearing would aid in resolving this case, counsel for the
parties may contact the Conciliator directly to schedule such a Conciliation
Conference.
cc:
Carol 1. Lindsay, Esquire
Jetfrcy S. Shank, Esquire
J.
Edgar B. Bayley
y
0-
l-:,.p 0 \
<< ()\.\~
r
\
MARVETI'A L. LANDER,
Plaintill'
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION - LAW
LEONARD G. LANDER, JR..
Ddcndunl
NO. 98 - 5746 CIVIL
IN CUSTODY
Prior Judgc: Edgar B. Baylcy
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH TIlE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
19 I 5.3-8(b), the undersigned Custody Conciliator submits the following report:
I. Legal counsel for the parties had a telephone conference call with the Conciliator and, based
upon that call, the Conciliator rccommends the entry of an order in the form as attached.
ill / 0/
D TE '
Hubert X. Gilroy, Esquire
Custody Conciliator
. '~. "..,
ORDER/NOTICE TO WlTlmOI 0 INCOME FOR SUPPORT
/).{!. ;', - '5. ;lYe.. (I/l'lt-
~)d.".., :( '/l( I' /(~
IV~ "1,"/,., >) > / I
State .rummonweallh of Penn..lvania
Co.lCilylDi,1, of CUMBERLAND
Dilte of Order/Notlcc 02/06/01
Court/Cfl\e Number (Sef Add(lndum for C'd.\fI sum"",ryJ
O(lm:'fl.ll(',d,'r,'NIlII'\'
o Am,'noll'd C l,d""~1l1lf"
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, ','
.,. p 1,'rnllll,lrl' (lrd,.,:Nlllll"
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[rnplllrN/\Vllhhl.lld,'(~ Ft'l!.'fJI UN NUfI\h',
.RI LANDER, LEONARD G. JR
111I1,11111"','( )hIWflr'~ '.11111' t.hl.' "..I. .\\1,
COMMONWEALTH OF PA
1''''I,lIIY'',I\V,'hhcl!",.,'..N.IIIll'
176-62-1890
Illll'lll\..,.'j )hll~:t'(' ....011,,1 ,u., Ufll\ Nll",I".,
C/O PAYROLL OPERATIONS
Elnl'lu\,I'rflNilhhnlrlt'r', Afll.n.....
PO BOX 8006
HARRISBURG PA 17105-8006
9701100108
11111'1(1\('\':1 1hll),:or\ (',I',' ld.'nhill'r
(!l'('f' AddMdum (or pldinli(( ndmN dfSoc1dlrd with CdS('f on dltdC'hmf.'ntJ
(1l~'odl.Jl P,HI'fI!''' "'.mlt' '\.I~I, !"."t, ,\\11
See Addendum for dependent names alld birrll dart.s associared lVillI cases 011 allacllment.
ORDER INFORMA TION: This is an Order/Notice to Withhold Incomc ior Support bilScd upon an ordcr for support
from CUMBERLAND County, Commonwealtlt 01 Pcnn,ylvania. By lilW, you arc rcquired to deduct these
amounts irolllthe above-named employee',/obligor', income until lurther noticc cvcn if the Ordcr/Notice i, not
issued by your State.
$ 924.00 per month in current ,uppo"
$ 20.00 per month in past-duc support Arrears 12 weck, or greater? 0ye, 0 no
$ 0.00 per month in medical ,upport
$ 0.00 per 1II0nth for genetic test costs
$ pcr month in other (specify)
for a total of S 944,00 per month to be forwarded to payee below.
You do not have to vary your pay cycle to be in compliilnce with the ,upport order. If your pay cycle does nol malch
the ordered ,upport payment cycle, use the foliowing to determine how much 10 withhold:
$ 217 85 per weekly pay period.
S 435.69 per biweekly pay period (every two weeks).
$ 472.00 pcr ,emimonthly pay period IIwicc a month).
$ 944.00 per monthly pay period.
REMITTANCE INFORMA TlON:
You mu,t begin withholding no later than the first pal' period occurring ten (101 working day, after Ihe date of Ihis
Order/Notice. Send payment within ,even (7) working days of the paydille/date of withholding. You are enlitled to
deduct a fee to defray the cost of withholding. Refer to the laws governing the work slate of your employee for the
the allowable amount. The total withheld amount. and your fee, cannot excccd 55% of the empioyee',/ obligor's
aggregate di'po,able weekly earning" For the purpose of the limitation on withholding, the following information i,
needed (See #9 on pg. 2),
If remitting by EFT/EDI, please call Penn,ylvania State Collection, and Disbursement Unit (SCOUI Employer
Customer SelVice at 1-877-676-9580 for instruction,.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P,O, Box 69112, Harrisburg, Pa 17106-9112
IN ADDITION. PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (sllolVn
above as tile Employce/Obligor's Case Idenrifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
DRO: RJ Shaddny MA.I.LED
xc: defeniant ...J r-- 1/
.....;.i.:.((
. L-))
BY THE COURT:
Date of Order: Febrmry 7, 2001
Eiwad E. Glli'~
JUDGE
Form EN-028
Worker 10 $IATT
SelVice Type M
- V
\,y
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ADDITIONAL INFORMATION TO EMPLOYERS AND OTHER WITIHlOlDlRS
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WITHHOLDER'S iD: 2321722990
EMPLOYEE'S/OBliGOR'S NAME: LANDER , LEONARD G. JR
EMPLOYEE'S CASE IDENTIFIER: 9701100108 DATE or SEPARATION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S NAME/ADDRESS:
6. lump Sum PJYIllp.nts: You n1.1Y he required 10 rt'porl Jlld withhold (ro111 lump "lllll pJYlllt'nls ..uch .1'" oOllu..e.., wtllllli..siom, or
St!verJl1re pJY. If you hJve Jny questions Jooullull1p ~um pJYIllp.nl"" {onIJ{ I tlw pf>rc,on Of Julhority I)plow.
7. liJhility: If you fJil to withhold income .1S the Order/Nolin:! directs, you .Uf' liJble fur both tilt' Jf( umulJled JlllOUllt you should
have withheld from the employee/obligor's income Jnd ollwr pt~nJlties set by PenmylvJniJ Stolte Iolw. PennsylvJniol StJle lolW goVt~rns
unless the ohligor is employed in another State, in whirh fJ\e Ilw 1,1W of the StJte in which he or she is emploYf'd governs.
8. Anli-discriminalion: You are subject to ol fine dett'rrnined undt'r StJlf' IJW for disrhJrging JIl employee/obligor from
employment, refusing to employ, or taking disciplillolry Jctioll Jgo.lil\st ,lilY ..mploype/llhligor IWfJLlSP oj J supporl withholding.
PennsylvJniJ StJte lolW governs unless the obligor 1\ employed in Jllother SIJtP, in \\'hich CJ\f' the IJW of Ihe StJte In which he or she is
employed governs.
9. '" Withholding limits: You may not withhold Illore IhJll Ih~ le\ser of: 1} Ihe ,1mOllnfs .llIow~d by Ihe FederJI Consumer Credit
Protection Art (15 U.S.c. S 1673 (b)1; or 2) Ihe amounts Jllowed hy the Sldtt~ of Ih~ ernployp.e's/oh1igor's principJI plJce of employment.
The Federal limit applies 10 the aggregate disposJble weekly eo.lrnings (ADWEl. ADWE is the net income left after making nlJndatory
deductiolls such ilS: StJte, Federal, local taxes; Social Security l.lxes; olnd Medico.Ire tJxes.
10.
'NOTE: If you or your agent are served with a copy of this order in the state Ihat issued the order, you are to follow the
law of the state that issued this order with respect 10 these items.
Requesting Agency:
DOMESTIC RELATIONS SECTION
P.O. BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions,
contact WAGE AlTACHMENT UNIT
by telephone at (717) 240-6225 or
by FAX at (717) 240-6248 or
by Internet @
Page 2 of 2
Form EN-028
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IN TilE COURT OF COMMON I'LEAS OF CUMIIEIU.ANU COUNTY, PENNSYLVANIA
CIVIL ACTION
MARVETTA L. LANDER.
Plaintiff
)
)
)
)
)
)
)
No. 98-574(, - Civil Term
vs
LEONARD G. LANDER, JR",
Defendanl
PETITION FOR MODIFICATION OF CUSTOUY
AND NOW, this
day of March, 2001, eomes the above-namcd Plaintiff, by
and through hcr attorncy, Jcffrcy S. Shank. Esquirc of Gingrich, Smith, Klingcnsmith & Dolan and
pctitions this Honorablc Court as follows:
I. Thc partics hcrcto arc thc parcnts ofRachcl M. Lander, born Novcmbcr 27, 1989.
2, On August 25, 2000, upon considcration ofa Pctitionto Modify filcd by thc abovc-
namcd Dcfcndant, this Honorablc Court cntcred an Ordcr of Custody by agrccmcnt ofthc partics.
A eopy of this Ordcr is attachcd hcrcto as cxhibit "A,"
3. Thc abovc Ordcr entcred on August 25, 2000, contcmplatcs thc abovc-namcd
Plaintiffs rcqucst to relocatc to Kansas with the subject minor child.
4. A hcaring on this mallcr is schcdulcd bcfore thc Court on March 2 1,2001 at 8:45 a.m.
and so the issue of rclocation is ripe. Mother filcs thc within Petition,
5. Mother believcs and thercfore avcrs it is in thc bcst intercst ofthc subject minor child
for Mother to continue to have primary physical custody and bc pcrnlillcd to rclocatc with thc
subject minor child to Kansas. Father has bcen onnoticc ofMothcr's dcsirc to relocatc since at least
August 8, 2000, the date of the most rccent custody conciliation confcrcnce.
..
I ~
I
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AlIu 2 4 20001/./
MARVErrA L.I.ANI>ER,
Plaintiff
IN TI IE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
v
CIVIl. ACTION - LA W
LEONARD G. I.ANDER, JRoo
Dcfcndant
NO.lJ8-5746 CIVIL
IN CUSTODY
COURT ORnER
AND NOW, this _~hday of August, 2000, upon consideration of thc attached Custody
Conciliation Rcport, it is ordcrcd tU1d dircctcd as follows:
I.
A hearing is schcduled in Courtroom No.2 of thc Cumberland founty Courthousc
on thc ry til day ofDcccmber, 2000, at g' '1..5 , J1.M. at which timc
tcstimony will bc takcn in thc abovc ca~e.
2.
The partics shall have another Custody Conciliation Confcrcncc via a tclcphonc
confcrcnce call with thc Custody Conciliator on Friday, November 10, 2000 at 8:30
a,m. Aftcr this Conciliation, thc Conciliator shall recommcnd a furthcr ordcr to the
Court with rcspect to the parties rcquiremcnts to file prc-hcaring mcmorandums and
any othcr issucs thc Conciliator feels necds to be addresscd.
3.
Thc partics shall submit thcmsclvcs and the minor child and any significant othcrs
that an evaluator dccms appropriate to a cus',9dY,cvaluation to bc perfonned by Dr.
Arnold Shcinvold. Costs of this evaluation S~I ~ split betwccn the parties with the
Father paying 65% and thc Mother paying 35o/q) It is dirccted that the custody
evaluation be completc with a writtcn rcport p ovided to the partics in advance of tile
Custody Conciliation Conference scheduled above.
4.
Pending furthcr Order of this Court, this Court's prior Order of December 16, 1998
shall remain in ",ffect su~ject to the following modifications:
A. Father's periods of temporary custody shall be on three out of four
weekends from Friday evening until Sunday evening at 8:00 p.m.
Two of thcse wcekends shall be the weekends the Mother is
working. The third wcekend shall be as agreed upon by the parties
with the parties to work this out at least threc (3) days in advance.
B. For purposes of cxchangc of custody, the Father shall be required to
handle all transportation on two out of the three weekends. On the
third wcckcnd, the Mother shall be rcquired to share the
transportation with either handling all transportation on Friday or
Sunday or the pqrties mecting at a mutually agreeable halfway point
bctween thc Mothcr's homc in Mechanicsburg and thc Father's
current home in Grcensburg.
EXHIBIT
i
.
"All
Lander v, Lander
Page 2
Additional Information: 1. Harrisburg Institute of Psychiatry (HIP), psychiatric
evaluation conducted by Dr, Richard Fonte, on Marvetta
Lander, dated Febrwuy 16, 1995
2. Discharge Swnmary from the Adult Partial Hospital
Program of HIP on Marvetta Lander dated March 20, 1995
3, Medical records for Marvetta Lander from Carlisle
Hospital
4. Initial Evaluation dated July 29, 1998 and Outpatient
Treatment Swnmary on Marvetta Lander provided by Edward
A Franco, Ph.D.
5, Therapy notes for Rachel Lander from Nancy Small,
ACSW
6. School Records from Shiremanstown ElemenlaJy School
for Rachel
7. Court Order dated August 25,2000
8. Court Order dated December 16, 1998
. The re~endations at the conclusion of this report are based on a careful
review of all of these sources of information.
'Background:
I.en and Marvetta Lander met in 1988 and were married on May 27, 1989 after
. Marvetta became pregnant with Rachel. At the time they met Len was in the army and
".' stationed in Missouri. However, after Rachel's birth, Le1lleftthe army and he and
, ;:'i~ettamoved to ,his parent's home in western Pennsylvania. Marvetta did not work at
, . that time. Len worked initially as a factO!)' worker and then as a guard at a correction8l
facility. Finally, I.en was accepted into the State Police Academy. He has been a State
Policeman ever since.
Lander v. Lander
Page 3
Following Len's graduation from the Academy he was stationed at the Carlisle
barracks. Therefore, Len and Marvetta moved to the Carlisle area in 1991 and were
living there at the time of their separation in 1998, They provided somewhat different
stories about the marital demise. According to Len the marriage was never very good.
He found Marvetta to be extremely volatile and emotionally labile. There were constants
fights in the marriage because of the amount of attention that Marvetta required.
Ultimately, Len established a relationship with his working partner, Sally Worst, and he
left the marriage.
Marvetta reported that she believed the marriage was relatively good. She
admitted that there was a lot of bickering and fighting during the marriage. She also
reported that the fights would, at times, become physical and both of them were
participants. However, it was not until the last three years of the marriage that Marvetta
felt that the marriage was in trouble. Marvetta was experiencing significant emotional
problems that required intensive treatment for depression. Marvetta "recalled" after the
birth of Rachel that her father had molested her as a child. Len was initially very
supportive of her problems. However, she reported that he became increasingly distant
and she suspected his relationship with Sally. She attempted to engage him in marital
counseling. That failed and Len left.
Len initially moved in with a friend. He would visit with Rachel as much as
possible, but he had no where to keep Rachel for overnight visits. It was not until he
moved back into the marital residence that he had a place to visit with Rachel.
Eventua11y, Len was awarded a1temating weekend visitation, Wednesday overnight visits
and alternating Thursday night visits. He reported that he would frequently see Rachel at
other times and considered himself to have a shared arrangement. '.
The relationship between Len and Marvetta post-separation was filled with
conflict. Marvetta was very hurt by the separation and angered by Len's new
relationship. Contact between Len and Marvetta often included angty interchanges in
front of Rachel. On one occasion Marvetta went to Sally's apartment with Rachel to
confront Len. Len made a decision to transfer from his criminal ll!vestigation unit to a
drug investigation unit. After two years he got the transfer and was assigned to the
Pittsburg region. It was as a function of that move that a conciliation conference was .
held to modify the custody arrangement. At the conciliation Marvetta declared that she
wanted to move to Kansas with Rachel.
.:.,,>,':' .
:...-......
Lander v, Lander
Page 4
This custodial evaluation was requested as a function of Marvella's request to
move out of the state. Len is opposed to such a move. He is generally happy with the
current custody schedule in which he has custody of Rachel three out of every four
weekends, He shares holidays and is allowed 2 weeks of vacation in the swnmer. He
would like to be able to spend additional time with Rachel in the summer,
Len feels that he should be the primary custodian if Marvella moves to Kansas.
He does not believe that Marvella will support a relationship between him and Rachel if
they move, Len feels that his relationship with Rachel cannot continue to grow if she is
that far from him because the frequency with which he will be able to see her will be
significantly reduced. Additionally, Len does not trust Marvetta's long term emotional
stability. He noted that she has a long history of emotional problems that have their cause
in abuse she suffered at the hands of her parents when she was a child. He does not
believe, therefore, that it is in Rachel's best interest to be raised in the environment where
Marvella'S abuse occurred.
Len has concerns about Marvella's parenting of Rachel. He reports that Marvetta
does very little limit setting with Rachel. He noted that Rachel does not have a regular
bedtime and is often awake until!! :00 P.M. on school nights. He reports that Marvella
will talk to Rachel as though she is a friend and look to her for support and
companionship. He believes that Marvetta has shared inappropriate adult information
about the divorce with Rachel.
On the other hand, Len feels that he can offer a stable environment for Rachel.
Len works a fairly regular schedule, and only occasionally has to work on weekends.. He
reported that he will have the support of his mother and father in the area where he now
lives. Additionally, Sally and he will be living together, thus providing another adult
available to care for Rachel. Len believes that he is better at providing the structure that
Rachel needs than is Marvella. Finally, Len and Sally have another child with whom Len
would like to see Rachel continue to bond,
It is Marvella's position that the only reason she originally moved from Kansas
was to be with Len. She has no family support in this area and does not feel attached to
Pennsylvania. Marvetta reported that she remained in the Carlisle area after the
separation so that Len and Rachel could continue their relationship. However, when Len
transferred to western Pennsylvania she could see no reason to remain in Mechanicsburg,
It is her belief that Rachel will be able to see her father during the summer and at
holidays and still maintain a similar relationship to what he has living near Pittsburg.
. '.~-
Lander v. Lander
Page 5
Marvetta does not feel that Len can serve as the primary custodian for Rachel. Sbe
points out that she has been a stay at bome mother for most of Rachel's life and that she
and Racbel have a strong emotional attachment. According to Marvetta, when Len was
living with them he was rarely involved with the care of Rachel. She admits that be has
become more involved since the separation, but the actual day-to-day care of Racbel has
still remained her responsibility, For example, Len has rarely been at school conferences,
doctor appointments or dentist appointments. Marvetta questions whether Len's job truly
has the flexibility to allow him to care appropriately for Rachel.
Marvetta admitted that her father was abusive to ber during ber childhood, but she
reports having resolved her various issues with her parents. She also reports that she has
a close relationship with her sister. Marvetta believes that she will be able to utilize the
no cost support of her family so that she can get a full time job, or go back to school. It is
Marvetta's contention that by doing that she will be significantly improving the quality of
life for her and Rachel.
Marvetta reported that Len has a bad temper and, at times, has a difficult time
controlling his anger, She reports that there was violence in the marriage on both of their
parts. However, Len's behavior improved when his drinking behavior decreased,
Nonetheless, he would continue to get angry and yell or break things in front of Rachel.
Marvetta feels that Rachel has been fearful of her father in the past.
Analysis and Recommendations:
One of the major concerns raised by Len was with regard to Marvetta's emotional
stability. Marvetta has a significant psychiatric history dating back to 1995. In that year,
Marvetta was experiencing syncopol episodes which led to a medical hospitalization,
These periods of "blacking ouf' appeared to be the result of a Major Depressive disorder
and led to a brief psychiatric admission and then extensive outpatient treatment.
During the course of her treatment, Marvetta was placed on antidepressant
medication. Her problems appeared to be, in part, a funCtion of physical and sexual . _. _
abuse that she suffered as a child. In addition to a diagnosis of Major Depression, .. .
Marvetta was also diagnosed as having a Dissociative Disorder and Post Traumatic Stress ..: ..':
Disorder. Marvetta remained in therapy on a decreasing schedule of visits over the next .
several years. During the worst times of her symptoms, Marvetta was having a difficult ,,-':
time dealing with R.achel's behavior, Nonetheless, she remained the parent primarily.
involved with her care. .. . .
. .-'.
Lander v. Lander
Page 6
At this point in time, Marvetta' s mental status appears to be more stable than it
was in 1995. She denies any current problems with depression or anxiety. Marvella
continues to experience physical problems which are probably stress related. However,
her symptoms do not interfere with her ability to work outside of the home, or to care for
Rachel. Marvella is able to concentrate well and she feels as though she has resolved her
issues with her parents.
Marvetta was articulate in her presentation of her perceptions of the situation. She
was able to assert opinions in an appropriate marmer. She maintained relatively good
eye-contact and her thinking was rational and productive. There were no signs of
delusions and she denied any ha11ucinatol)' symptoms. Marvetta is currently working
outside of the home and experiencing no problems at work. .
Marvetta's MMPI-2 results are valid. Her profile is associated with someone who
is being somewhat defensive in responding to questions. These individuals are trying to
present themselves in a favorable light. This profile is consistent with an individual who
is likely having periodic anxiety attacks. The anxiety may actually present itself as
irritability in interactions with others. These women often seek attention and approval,
often at the expense of personal values. They tend to be somewhat immature,
suggestible, and naive. Marital discord is common amongst this group of women and
they are likely to have a histOI)' of rejection by their fathers. They tend to use repression'
and denial in dealing with problems. Therefore, they often lack insight and express their
needs unconsciously or indirectly. Physical symptoms tend to develop as a function of
stress. Diagnoses associated with this profile generally reflect the problems with anxiety
and the tendency to displace psychological problems into physical complaints.
Marvetta and Rachel have a close emotional attachment. Most of the attachment is
a function of the large amount of time that they have spent together. As mentioned
earlier, Marvetta has always been in the role of primary care-giver. This was especially
true when Rachel was an infant and Len was in his early career with the State Police.
There was a period of time when Len became more involved in Rachel's care. The result
of that time was that Rachel also has a good relationship with and is attached to her
father. However, during the periods of marital distress, Len again tended to absent
. himself from the family.
The strength of Rachel's attachment to her mother is noted in her testing and
. interviews. Rachel indicated that her mother has been the parent who was most. involved
in caring for her and playing with her. Rachel very much enjoys her time with her father,
Lander v. Lander
Page 7
She noted that her father is now more apt to play games with her than he was in the past.
She also enjoys the individual time he gives to her when Sally is not around. However,
Rachel perceives her father as having a temper and being angry more often. Rachel
reported that she is fearful of her father's anger.
Rachel sees her mother as more nurturing and comforting to her. She believes that
her mother better understands her moods and is more willing to listen to her. Rachel's
BPS scores are entirely oriented towards her mother. While it is not believed that there is
as great a discrepancy in the parents' ability to care for Rachel as is reflected in these
scores, it is genuinely a reflection of Rachel's preference to be primarily with her mother.
The same is true of Racbel's respon.scs on the Parent Report Card.
There is some concern about the appropriateness of Marvetta's emotional
attaclunent to Rachel. Marvetta, at times, has utilized Rachel as a confidant and shared
inappropriate infonnation with her. Marvetta once took Rachel to Sa/Jy's apar1ment
while Len was there and exposed her to the conflict of that situation. Marvetta has also
talked negatively about Len and Sa/Jy in front of Rachel. There is no question that this
behavior is inappropriate and reflects poor judgement. Marvetta appeared willing to
admit that her behavior was, in fact, inappropriate. She related that that type of behavior
was present initia/Jy in the separation, but that she is no longer doing those things.
Fortunately, her behavior has not led to alienation of Rachel from her father.
There is no question that Len loves his daughter and wants to do what is best for
her. His concerns regarding his daughter's welfare and his future relationship with her
are genuine given the current situation. There was nothing in Len's psychological profile
that would preclude him from being able to provide adequate and appropriate care for hiS
daughter. Len has cared for Rachel by himself at many different times in Rachel's life
without any concerns about the Care he provided. The only issue that was raised as a
function of the interviews with Rachel was her report about her father's tendency to
become easily angered. Given Rachel's age and sensitivity, she appears to be negatively
affected by that aspect of his personality.
Len's MMPI-2 results are totally within nonnal limits. He took a relatively
balanced approach to answering questions. There is some indication in the profile that he
may have periods of somewhat impulsive behavior. The profile is associated y,ith
individuals with fairly high energy levels, who are generally optimistic and enthusiastic:
However, they may experience some interpersonal problems due to and overly assertive
attitude. There are no psychiatric diagnoses associated with this profile. .
. '".
Lander v. Lander
Page 8
Interestingly, during Rachel's interviews, she listed her priority of possible
outcomes in this case. Rachel's first preference would be to remain in Mechanicsburg
living with her mother. Although Rac:hel has not done well in school, she likes her
current school, especially the teachers and her friends. It seems like an enonnous task for
her to have to move to a new area and make new friends. This is a common response in
any child faced with the task of moving,
Rachel's sccond preference is to move to Kansas with her mother. Although she
does not want to move, she clearly fears not being in the primary care of her mother,
This is a reflection of the depth of the emotional attachment to her mother. She loves her
father and would like to continue to visit with him as she presently does. However, she
believes that she would miss her mother vCl)' much if she was living full.time with her
father.
Given all ofthesc factors, it is recommended that Rachel remain in the primary
custody of her mother. Without a doubt, it would be better for Rachel's relationship with
her father if she and he remained in the same city. Unfortunately, that possibility was
eliminAted when Len elected to be transferred to the Pittsburg region. Len admitted that
part of the reason for his move was to distance himself from Marvetta. The other part
had to do with getting new experiences in his job and being closcr to family. He felt that
Marvella's behavior towards him was harassing and too difficult to deal with on an on.
going basis. He was willing to sacrifice mid-week access with Rachel in order to
eliminate that level of conflict. Obviously, he wanted as much weekend visitation as
possible.
It scems somewhat unfair to block Marvella from making a move to a location that
she finds more supportive and replete with new job possibilities when Len moved for
vCl)' similar reasons. Just as Len's move led to a need to modify the custodial
arrangement that existed, a move to Kansas by Marvetta would necessitate another
modification. It is not believed that Marvella's move would destroy Len's relationship
with Rachel. Rachel is not currently alienated from her father. She has an emotional
attachment to him and enjoys the time they spend together, The key in any modification
would be to allow enough time for the two of them to continue to eIlioy the time together,
and to allow Len to remain a primary influence in her life,
If the Court allows Marvetta to move, then it is recommended that Rachel be in the
custody of her father for eight (8) weeks during the summer. His summer access time
.should begin on the Saturday preceding Father's Day and continue for the next 8 weeks,
Lander v, Lander
Page 9
Marvetta should be allowed to visit with Rachel for one weekend during that time.
However, that visit should occur in the area in which Len is located.
In addition to the Summer access schedule, Rachel should spend time with her
father during every Christmas recess. In 2001, and every odd year thereafter, Rachel
should visit her father beginning on the last day of school and continuing until December
31", In all even years, Rachel should visit with her father from December 26th until
January I". Additionally, Len should have the option of having time with Rachel at
either her Thanksgiving break, or her Spring break. The parents should agree in advance
which of these times works best for them and the time should be maximized to provide
far the longest period of time for Rachel and Len. Len should also have the option of
visiting Rachel at any time in the city where her mother is residing.
It will be imperative for Marvetta to supply up to date infonnation for Len
regarding Rachel's schooling, extra-curricular activities, medical and dental information.
Additionally, Len should be allowed liberal phone access to Rachel, such that Marvetta .
insures that Rachel is available for set phone calls with her father. If at all possible, it
would be beneficial for Len and Rachel to establish an e-mall contact through the
Internet. This would be an excellent way for them to maintain an on-going relationsbjp.
Move away cases are extremely difficult to deal with. There is never an ideal
option for custody because the distance between parent and child inherently changes the
nature of the relationships. The recommendations above are suggestions to be used as an
outline in designing a custodial parenting plan that will maximize time for Len and
Rachel.
/ '- (, <' Lo
Dated
~w /' L .:,r:O rz 'J.
old T. Shienvold, Ph.D/
Rue 02 00 09.468
Rlecler. Shtenvotd L R550 717-540-1416
Pa~e 2
Consultant
Centrn1 Dauphin School District
Harrisburg, PA.
p,3
Aug. 1982 - June 1987
Co-Director
Center for Behavioral Medicine
Polyclinic Medical Center
Harrisburg, P A.
1982 - 1985
Consultant
Cardiac Treatment Centers
Camp Hill, P A.
Sept. 1978 -1985
Adiunct Professor~hip Aug. 1977 - July 1984
Department of Behavioral Science, Dept. of Family Practice
Hershey Medical Center
Hershey, PA.
Resource Psycholojpst
Ridgecrest Children's Center for Emotionally Disturbed Children,
Tuscaloosa, AL
Developing treatment plans for 10 - 13 year old children, training staff
in implementation and providing individual and group psychotherapy.
PROFESSIONAL AFFILIA nONS
Board of Governors, American Academy of Family Mediators
Association of Family and Conciliation Courts
Diplomate, American Board of Forensic Examiners
Academy of Family Mediators - Practitioner Member
Pennsylvania Psychological Association - Fellow
American Psychological Association
Association of Family and Conciliation Courts
1996 - Present
1993 - Present
1996 - Present
1985 - Present
1985 - Present
1976 - Present
1993 - Present
Rue 02 00 00.468
RI.el.~. Shl.nvold 'R..o 717-540-1416
l'a~e 3
WORKSHOP PRESENTATIONS:
Presenter
Presenter
Presenter
Presenter
Co-Presenter
Workshop Leader
Workshop Leader
Workshop Leader
Panel Member
Institute Leader
Presenter
Evaluating Mobility Cases, AFCC Conference
June 1999
Ethical Issue in Custody Evaluation and Mediation
Michigan Association Court Mediators, September 1999
Evaluative Mediation, Wisconsin Association of
Mediators, November 1999
The use of Question in Family Mediation
Virginia Mediation Network, November 1999
Ethics Forum, Academy of Family Mediators,
San Diego, CA. 1996, 1997
Pulling the Data Together. AFCC Custody Conference,
Breckinridge, Colorado, September 1997
Evaluative Mediation, Academy of Family Mediators
Cape Cod, July 1997
Integrated Model of Custody Resolution, Association
of Family and Conciliation Courts, Clearwater, FL.
January 1996
Hot Issues in Custody, Pennsylvania Bar Institute
Fall 1995
Duel Roles in Custody Conflicts, Academy of Family
Mediators Conference, Cincinnati, OH., July 1995
Family Me.diation - Central Pennsylvania Paralegal
Association, October 1993
p.4
Rue 02 00 09.478
Panel Member
Workshop Panelist
Workshop Panelist
Workshop Panelist
Seminar Leader
Seminar Leader
Shienvold, AT.
Shienvold, AT. and
Asken, M.A.
Shienvold, AT.
Shienvold, AT.
Rleeler, 5hlenvold L A~~o 717-540-1416
Palle4
Conflicts, Problems and Ethics in Custody Evaluations
June 1995. Pennsylvania Psychological Association
Annual Meoting, Harrisburg, PA.
High conflict custody cases: Association of Family and
Conciliation Courts annual conference, New Orleans, LA.
April 1993
Custody Litigation, Evaluation, Mediation:
Cumberland County Family Law Division, May 1992
The Use of Psychological Testing in Custody Evaluation,
Pennsylvania Bar Association, May 1991
Psychologists in Family Medicine. Society of Teachers
of Family Medicine, San Diego, CA. May 1978
Stress Reduction, Hershey Medical Center
ijershey, PA. 1978
Why research is not done in family practice residencies.
Presented at Pennsylvania Consortium of Family Practice
Residencies, Hershey, PA. September 1977
Resident view of their behavioral education, Assooiation
of behavioral Sciences in Medical Education.
October 1977.
Medical Psychology: The role of the psychologist within
the hospital. Presented at Northeastern Association of
Operating Room Technicians, Harrisburg, PA February 1978.
A dual focus behavioral science curriculum. Symposium
of APA meeting. Toronto, Canada 1978
p.5
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CONDITJ:ON AT TDm OJ!' PROCBDORE/TRXATMllNT
"'2.-
lB"' UNCBANGBD
,.
late of Surgery/Procedure
'Admieeion/Preop Diagnosie
'CC/HPI
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,P
Mental Status
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Lungs
ther
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R Temp
-General Condition
Wt.
Planned Treatment/Procedure
'\'//'1./9'1
E
DATll
INJ:TJ:ALS
ColmlPlete a],+ s.tarred., ALL patients, Complete
a other l~es pert1nent to patients
planned procedure or medical condition.
.1!'It\ Carlisle Hospital
~, and Health Services
AIalIlLATORY CARB RECORD
.f:-
m4~~ ~~HARVETTA L.
~ OS/14/QQ SQs GENEVA OR UNIT 11
i? J,...., .-J~O~1..~CHANICS8URG. PA
~ ...:)iEI;6 EJr. HILIP A
_, " 2 11 9 Y19Yb8.
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(1/96)
,.
MASLAND ASSOCIATES. INC.
INTERNAL MEDICINE
MEDICAL ARTS BUILDING
DAVID S. MA5....No. M.D,
RETI.ED
JOSEPH F. B'AZEL M,O,
/lEMA TOLO<lV
FRANK P. CASTRlN... M,O.
PuLMONARY
220 Wn,SoN STREET. CARUSLE. pA 17013
.....y S. RANKIN. M.D., F,A.C.C,
C.4RDIOlOOY
DURA 0, TAYlOR. M,D.
JNnRN.\L MEDICINE
Ll.m:R L HU""ElJUlCH. W. M.D., F.A.C.P.
INTERNAL MEOICIP'IIE
(717) 249.1929
TE'RY A. ROIl5ON. D.O.
INTERNAL MEDICINE
PHIU' A. NEIDERtR. D.O.
I"'TIRNAL MEDICINE
DOUG...... J. BowER. M.D.
INTERNAL MEDICINE
PATIENT:
STUDY:
DATE:
DOB:
DICTATED BY:
Marve t ta Lander
History and Physical Exam
May 6, 1999
10/08/64
Lester L. Himmelreicb, III., M.D.
This is a 34-year old lady with a past medical history of mild obesity and
mild hypothyroidism who is here for a pbysical. The patient has bad a
fairly rough last year related to domestic problems, i.e., pending
divorce, sexual harrasment at work, her current boyfriend moving out on
her. She keeps her 9-year old child from her previous marriage. Sbe
has a potpurri of problems, she has had Some dysphagia and recurrent
nausea and vomiting, says sbe vomits all PO intake, although 8he has not
been losing weight. The last time she had Some hematemesis. She has
been on Pepcid in the past but stopped it. Did she have a hiatal hernia _
well, she is not sure.
SH: Doesn't smoke, she drinks 3 to 4 beers a week.
CURRENT MEDICATIONS: Celexa 20mg a day, she is allergic to Codene.
PSH: Tubal ligation and a C-section.
FH: Mother 58, colon problems. Father 58, hypertension and "heart disease"
and colon problems. She's got two sisters who are alive and well.
ROS: She work for Rite-Aid. She has a daughter who is age 9. She gets
occasional dizziness, she gets some palpatations. She has questionable
hiatal hernia. Her last normal menstrual period was about 2-weeks sgo.
She was sexually active until recently, she has had a tubal ligation.
I . .
~: ,Shii:; clearly looks -d';'pressed': i:~ ine," Blood pressure on recheck 130/90.
Pulse '80, .\t:,esp. 20;. she :is.. afebrile.,
~ ~ I J I ~. .
,..". II -
BEENT - TMfs~t-el c~ear. Nasomucosa was pink. Pharynx looks okay. Dentition
is good. Pupils equal and reactive to light. Extraocular muscles intact.
Sclera white, conjunctiva pink. Neck supple, carotids 2+ without bruits.
Trach~~ ~dline. JVD none. Lungs clear. Heart normal. Breast exam with
Molly in the room, no masses, no nipple discharge, Belly soft, nontender,
no organomegaly, No suppression splash. No bruits.
Rectal - not done. Plevic - normal female external genitalia, Cervix seen.
PAP taken. Bimanual benign. No adnexal tenderness, no masses. Extremitie8
are without cyanosis, Clubbing or edema. Neuro ia grossly normal,
.
Marvetta Lander
· His tory and Physical Exam
May 6. 1999
Page 2
IMPRESSION:
1. Recurrent nausea with hematemesis. Despite a tubal ligation ve vill
get a pregnancy test. Assuming this is negative, I think this is all
stress. She sees Ed Franco on a regular basis. She is on anti-depressant.
I vonder if the dose should be increased. I suspect that the recent
break-up vith her boyfdend on top of her pendinR divorce and her lack /
,or C~osen.BS to her tam1!v has ~ed to this depression. She is actually
due to see Ed Franco today and she is' enCOUraged to continue to see him.
2. Hypothyroidism - ve will check a TSH today in light of the hematemesis,
check a CBC and a Chem profile. See her back in about 2-weeks.
LLH/gav
T: 5/11/99
Lester L. Himmelreich, III, M,D.
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t::J' and Health ~JVIces
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CONVE;r,E~/cARE/EMERGENCY REGISTRATION
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LANDER, MARVETlA L.
~9~,OEN[VA DR ,UNIT 11.,
......../AllOMI.'~/llCUhOH/DO. /I(IC.Ir:CHJ
LANDER JR, LEONARD G.
125 STEELSTONN RD
NENUILLE, PA
.......,AOf-e..'I'tOll'..UN>>lIIOC-SICHO
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NONE
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RITE AID I
MECHANICES8URG, PA
176-62-1890
CARLISLE, PA 17013
17241
[YEl'Gl!HCVNOT1N
LANDER JR, LEONARD
(717)776-6027
. 02
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LANDER JR, LEONARO G. 02
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IN FIGHT N/HUSBAND, NECK A
NO FACE TURNED OPPOSITE i
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FEHRENBACH, DONNA M. D~
HIMHELREICH, LESTER ~
ASS II VISIT 26720
ASS III VISIT 26730
ASS IV VISIT 26740
ASS V VISIT 26750
INVENIENT CARE I 27020
INVENIENT CARE II 27025
~OR SUTURE EDSOl
'DIUM SUTURE EDS 02
JOR SUTURE EDS 03
'UBATIDN EDS 04
lETUP EDS D6
RDIAC MONITOR EDS 11
I.VIC EXAM EDS14
'RO SET.UP EDS16
ST. SCOTCH SHORT ARM 26031
ST. SCOTCH LONG ARM 26032
ST. SCOTCH SHORT LEG 26033
ST. SCOTCH LONG LEG 26034
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KIDDE TOURNIQUET
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In addition to feeling depressed, she describes her mood as angry
and irritable. She notes decreased libido and positive suicidal
idmation. She feels that her plan would be to use a gun which i.
available at home, but denies active plans, and her husband has
hid the bullets to his gun. There is no history of prior
attempts.
PAST HISTORY
Patient is second of 3 Siblings. She reports that starting at
age 4, she was the victim of repeated physical abuse from her
father. Abuse included frequent episodes of punchino. sl~priqg,
and being tl1rown agatll>>t t:,.. woo!! 'tor mlnor lncidents. Thi31 '
phytH-e-..1-atJ....... "''''nLl'''......J L wuugh",ul: Cnlldhood until she left the
home at age 18.
She reports being very lonely as a child and having a number of
imaginary playmates. Her mother remarks that her playmates were
always "getting hurt", Llsually in a very serious way, although
the patient denies hospitalization or visits to the emergency
room aSQociated with her abuse.
FAMILY HISTORY
There is a family history of alcoholism with both maternal
grandparents, and a maternal aunt has a hi story of e)(cessi ve'
gambling. Her mother was hospitaliZed for 1 week, 8 years ago
during a marital separation which involved repeated medication
overdoses.
PERSONAL HISTORY
Marvetta has been married 6 years. Her husband is 26 and is a
Pennsylvania State Trooper. They have a 5-year-old daughter who
was described as "being difficult" and as haVing daily temper
tantrums.
Patient has a high school diploma and has been employed by the
Holiday HoiIir Salon since AUg~lst, 1994.
!'1EDICAL HISTORY
As mentioned, she hoils had neurological consultations for her
syncopal episodes with no apparent diagnosis or treatment in the
past. This inClUdes, E.E.G, MRI, and CT scans as previously
noted.
Past psychiatric history inclUdes a trial of Prozac, 40 mg for
apprOXimately 12 months. The patient states that there Was some
initial success, but that she eventually became depressed again.
.'
In January, 1993, she underwent a psychiatric evaluation and was
started on Paxil, 20 mg.
Patient reports that she will have an occasional beer. There was
a time between ages 20 and 22 when there was excessive alcohol
consumption associated with blackout episodes. In addition,
there wall occasional use of drugs that include cocaine,
amphetamines and marijuana.
MENTAL STATUS EXAMINATION
Patient was an alert and cooperative young woman. Speech was of
a normal rate and tone. Mood was depressed. Hypersomnia,
increased appetite and decreased energy was noted. Patient
admits to having feelings of hopelessness with occasional
suicidal ideation. Hallucinations or delusions were denied.
Memory was grossly intact.
DIAGNOSTIC IMPRESSION
This is a 30-year-old woman who reports chronic symptoms of
depression with recent worsening and biological symptoms over the
past year or 50. While there was some initial improvement with a
trial of Prozac, when seen today, she remains significantly
depressed. The Beck Depression inventory was equal to 33.
In addition, there are symptoms of syncopal episodes with no
apparent organic causes determined at this point fn time. In
addition, there is a childhood history'of excesllIive physical
abuse with the possibility of trauma contributing to her current
symptoms.
DSM- I V 0 I ASNOSES
Ax i 5 I
./'
Dysthymia
~Major Depressive Disorder-partial treatment
treatment resistant
./Syncopal episodes - unknown etiology
V RIO Conversion Reactions
or
RECOMMENDA TI ONS
The patient has recently been started on Effexor, 37.5 mg, BID
and this will be continued. In addition, she is on Deyrel 100 mg
q hs. I suspect that we will gradually increase the Effexor
during her course in her program here. She will bm admitted to
the Adult Partial Hospitalization Program to continue regulation
of medication and exploration of issues that may be contributing
" ho, d."o..',o ood 'yoo"O' .:~:::::~'!~~_tl1_:_______
Richard onte, M.D.
,
ADULT PARTIAL HOSPITAL PROGRAM
HARRISBURG INSTITUTE OF PSYCHIATRY
DISCHARGE SlJItoIARY
Name: Marvetta Lander
Date of Admission: February 17, 1995
Date of Discharge: March 20, 1995
I. Psychosocial Summary
History of Presenting Illness:
. Marvetta Lander is a 30 year old woman who was referred from the
psychiatric unit of Carlisle Hospital where she was a patient from
2/12/95 to 2/16/95.
Marvetta presented to the medical unit of the Carlisle Hospital on
2/9/95 following a series of syncopal episodes at work. She noted
that these episodes had begun approximately two years ago and occurred
at the frequency of one episode every two or three months. They
increased in severity and frequency ending in hospitalization at
Carlisle Hospital.
Neurological consults and tests were administered with negative
findings.
Upon psychiatric evaluation on intake, Ms. Lander related she had been
depressed all her life with depressive symptoms worsening over the
past year.
At evaluation she was positive for suicidal ideation without history
of prior attempts. She considered using a gun. Her plans were not
active and her husband had hidden the bullets to his gun. Her husband
is a state policeman.
Past psychiatric history included a trial of Prozac 40 mg. for about a
year. In January of 1995, she was placed on Paxil 20 mg.. She saw
Dr. Manfredi while in Carlisle.
Treatment Course:
Transition/participation in proqram: Marvetta made a favorable entry
into the Partial Program. She was verbal and open and immediately
focused on syncopal episodes and prolonged intense childhood abuse.
She was obviously angry in affect and with reported behavior toward
her husband and daughter. She connected her current anger toward
unresolved anger and rage toward her mother and father. She expressed
. .'
Marvetta Lander, C' . lnued
page 2
'.
and demonstrated global guilt, and was exceedingly hopeless at the
start of therapy regarding her ability to recover.
Goals: Long term goals were: (1) to come to terms with issues
regarding father, (2) to deal with anger toward mother, (3) to
overcome depression.
.
Therapeutic goals as established at 2/21/95 treatment planning session
included: (1) to stabilize mood, weight and sleeping, (2) to reduce
guilt with no evidence of suicidality, (3) to increase concentration
and energy, (4) explore and reduce symptoms of dysthymia: (a)
hopelessness, (b) over-eating, (c) low self-esteem.
Therapv issues: Psychosocial stressors included: (l~raising
da~g~ter and inanility to nea' with diught9~'~ tem~, (2) feeling not
helped by husband, (3) screaming and yelling at home, (4) unresolved
issues with parents, (5) some conflict with older sister.
Response to therapy: Marvetta had some emotional ups and downs during
therapy with two syncopal episodes, periods of anger, running to a
corner and absences where she overslept. She had initial difficulty
with what triggered her angry outbursts but worked through issues of
how frustration and neglect caused her to: (1) pass out, (2) sleep,
(3) scream and become rageful. Her frustration and neglect was
directed toward her husband with whom the patient felt unsupported.
Two couples sessions were held (2/24/95, 3/13/95) and the couple
worked through areas of conflict fairly well. Marvetta addressed
issues of frustratinn with da'lgnter: and was committed to attendinq
Parents Helping Parents. Issues of anger and rage to ard parents w~re
addressed and Ma yetta remained open to 10n term resolution
maSSlve a use and neg ect y er paren s.
Psvchologica1 testing: Pre-Beck Depression Inventory score = 33, post
Beck = 8.
Her 2/17/95 MIlPI indicated: (1) elevated scales indicate the ~.
pr, r1 ing personality disorder (2) profile
indicates the presence of epreSSlve ymp oms either due to restraints
placed on inappropriate behavior or due to a chronic state of
depression and unhappiness without antisocial acting out, (3) high
degree of agitation and anxiety, as well as attention and
concentration problems. Judgement may also be impaired. (4) Doesn't
endorse a typically female role model and may show an increase in
anXiety or aggressiveness if expected to act according to a
traditional female role, (5) evaluate for suicidal ideation based on
possible impulSivity.
Admission Diagnosis:
Axis I -~ysthymia
J Major Depression - treatment resi stant versus partial
response
Syncopal Episodes - RIO Conversion Disorder
R/O Post Traumatic Stress Disorder
Marvetta Lander, c 'inued
. ~age 3
Axis II - Deferred
Axis II I - None
Recommendations:
Follow-up plans:
1) Outpatient individual therapy with Wendy Minnix
2) Medication follow-up with Dr. Manfredi or primary care physician,
Dr. Phelan.
3) Community support through Parents Helping Parents.
Therapy issues:
1)
..;;)
Marital issues with strong recommendation for couples counseling.
Relationship with daughter and patient's frustration with
mothering.
Long term unresolved conflicts with parents.
J3)
4)
5)
,Monitor syncopal, anger and relationship between the two.
Need for support system outside the home.
II.
Psychiatric Summary
Treatment Course:
.:......
Ms. Lander was admitted to the Day Treatmant Program with symptoms of
worsening depression over. the past year inclUding depressed and
irritable moods, suicidal ideation without active intent or plan, poor
energy, .increased appetite" increased sleep, feelings of hopelessness'
and poor libido. She was referred after a psychiatric hospitalization
after intensive medical work-up of syncopal episodes revealed no
medical etiology. She has a history of childhood physical abuse. Ms.
Lander initially was admitted on Effexor 37.5 mg. twice a day.
Ms. Lander was somewhat guarded in the group experience. She was able
j to discuss her history of severe childhood physical abuse and sexual
assault, as well as her restrictive adolescence. Initially, she would
speak about all of these events in her life without much display of
affect" and stated that she would often think about these things in
the second person and not feel the emotions associated with these
times. We discussed with Ms. Lander how her syncopal episodes may in
fact represent an intense reaction to stressful emotions, such as
anger, frustration or hurt, and it appeared that they would occur in
conjunction with such emotions. She continued to feel depressed with
low energy, poor appetite and increased sleep. We increased with
Effexor to 37.5 mg. in the morning and 75 mg. at h.s., and also added
,".;._.;._.-
\,
. .
Franco Psychological Associatcs
26 State Avenue, Carlisle, Pennsylvania 17013
Outoatlent Treatment Summary
.. .
CUent's Name: Marvetta Lander
Date of Birth: 10/8/64
Diagnosis: 300.40 Dysthymic
Following our initial evaluation on luly 2Q. 1998, Marvella presented for weekly .-/
psychotherapy sessions. At this initial stage of her separation from her husband Len, she
was extremely emotionally labile. She had thoughts of self-destruction as well as intense
anger towards Len. Marvetta made every attempt to engage Len in conjoint therapy. Len
made clear he was unwilling to give up on the affair he was having with a co-worker. It
became quite clear that Len was not interested in working on the marriage.
Marvetta turned much of her emotional energy into anger and provocative blaming with
Len and subsequently became involved with another man. Marvetta showed very
appropriate concerns regarding her daughter Rachael's adjustment to the divorce and y
sought psychotherapy for Rachael with Nancy Small, A.e.S. W., Licensed Social Worker,
at this office.
During October and November, both Len and Marvetta engaged in a good deal of
provocative emotional conflict. Marvella periodically became quite depressed, although
she used her new relationship with "Jim" to help her emotionally separate from Len.
Marvella did make the positive step of finding a full-time job and establishing a stable
home environment for RachaeI.
Following this period of regular sessions, I h olal of6 sporadic ses~ions intenupted
with no shows with Marvetta throu u w' r Marvetta to stay
tne'lse" nn her own emotional growth and often she would contact me when she felt .h-,,~
was in crisis.
My final diagnostic impression was Dysthymic Disorder with Mixed Personality Traits /
(d~-~~]4~/M
Edward A. Franco, Ph.D
Licensed Psychologist
riEFl!Nr:)~'..'3swrii
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Franco Psycbological Assoc:Jates
26 State Avenue, Carlisle, Pennsylvania 17013
InItial Evaluation and Trtatment Plan
Client's Name: Marvetta Lander Evaluation Date: 7/29/98
Primary DIagnosis: 300.40 Dysthymfc ClleD'l's Date ofBlrtb: 10/8/64
Problem Area/Symptoms: Depression, anxiety, relationship problem, extreme low self-
esteem, history of sexual abuse.
Client's Presenting Concern: Breakup of marriage '
Primary Clinical Symptoms: Depression and anxiety
1. Current Mental Status Evaluation: Marvella was casually groomed/dressed. She
was cooperative. Her motor activity was agitated, her affect was labile, her mood was
depressed and a:IXious. Her speech was nonnal, her thought process was intact. She had
no hallucinations or delusions. There was no suicidal or homicidal ideation present.
Marvella feels overwhelmed.
There was no impainnent in her self-perception, she was fully oriented and her memory,
judgment and insight were intact. Her cognitive function was intact.
2. Central Life Role Function Assessment: There is a mild functional impainnent
because of a new job. There is severe functional impainnent due to the recent breakup
with Marvella's husband. She has mild functional impainnent in the interpersonal/social
and self-maintenance areas of her life. She has a moderate impainnent in her global
central life function.
Relevant Psychological/Social History: Marvetta Landers is a 33 year old, currently
separated female who is married to Len Landers, a Pennsylvania State Policeman.
Marvella grew up in Kansas City, Kansas, and has an older sister, age 37, and a younger
sister, age 26. Her parents were ma!:1"kd for 28 years before her father left her mother.
.!!e ultimately married a 20 year old ,g!I:Lapd !!Q.YLbas, a.3.!6.Y-.e!l!.01!:'-cJ~l!ghter.
Marvella and Len were married 9 years ago and have an 8 year old daughter, Rachael. At
the time ofRachael's birth, Marvella had disturbing memories and thoughts of being
inappropriately touched by her father. This led to her strong feeling that her father
repeatedly sexually abused her during early childhood.
She had gone through 8 months of psychotherapy but felt her treatment did not address
her history of abuse. Recently she went through some marital cOWlSeling with Deb
Snelson that was not satisfactory.
,.' .
. .
\. .
Franco Psychological AlIsoclates
26 State Avenue, Carlisle, PennsylvanIa 17013
[nltlal Evaluation and Treatment Plan
CUent's Name: Marvella Lander Evaluation Date: 7/29/98
Primary DiagnosIs: 300.40 Dysthymic CUent's Date orBlrtb: 10/8/64
Problem Area/Symptoms: Depression, anxiety, relationship problem, extreme low self-
esteem, history of sexual abuse.
Client's Presenting Concern: Breakup of marriage '
Primary Clinical Symptoms: Depression and anxiety
1. Current Mental Status Evaluation: Marvella was casually groomed/dressed. She
was cooperative. Her motor activity was agitated, her affect was labile, her mood was
depressed and anxious. Her speech was nonnal, her thought process was intact. She had
no hallucinations or delusions. There was no suicidal or homicidal ideation present.
Marvella feels overwhelmed.
There was no impairment in her self-perception, she was fully oriented and her memory,
judgment and insight were intact. Her cognitive function was intact.
2. Central Lire Role Function Assessment: There is a mild functional impairment
because of a new job. There is severe functional impairment due to the recent breakup
with Marvella's husband. She has mild functional impairment in the interpersonal/social
and self-maintenance areas of her life. She has a moderate impairment in her global
centraIlife function.
Relevant Psychologieal/Social History: Marvella Landers is a 33 year old, currently
separated female who is married to Len Landers, a Pennsylvania State Policeman.
Marvella grew up in Kansas City, Kansas, and has an older sister, age 37, and a younger
sister, age 26. Her parents w~ 28 years before her father left her mother.
.!!e ultimately married a 20 year old 8i!L8!ld nQ.W"bas. a.3. V:lY-.e!II.olg.JJ~l!8!!~I.
Marvella and Len were married 9 years ago and have an 8 year old daughter, Rachael. At
the time ofRachael's birth, Marvetta had disturbing memories and thoughts of being
inappropriately touched by her father. This led to her strong feeling that her father
repeatedly sexually abused her during early childhood.
She had gone through 8 months of psychotherapy but felt her treatment did not address
her history of abuse. Recently she went through some marital counseling with Deb
Snelson that was not satisfactory.
I.
Psycbologlcal History (Including Family Members): History of sexual abuse.
Depression, low self-esteem. Hislory of medication with Prozac, Tegralal and others.
Mother had 7 suicide altempls and appears to have had borderline features.
CUBical Formulation: HislQry of ablUle has contributed 10 low self-esteem, chronic ~
depression, and insecurity. This insecurity has led to somewhal irrational jealousy with
husband.
Treatment Goals: Address her depression, work Inwards grealer individuality and deal
with anxiety.
Treatment Plan: Individual psychotherapy. Will reconsider referral for medication
through PCP, Dr. Himme1reich.
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BY,!'LY TO CARLISLE
March 22, 2001
The Honorable Edgar B. Bayley
CUMBERLAND COUNTY COURT HOUSE
One Courthouse Square
Carlisle, PA 17013
RE: landerv.lander
No. 98-5968 Civil Term; Divorce
Dear Judge Bayley:
After the opportunity of closing yesterday afternoon, I advised counsel that there
were a couple of cases I wanted to bring to the Court's attention. These cases state
what has become nearly a black-letter law in Pennsylvania, but in a case like the lander
case, with competing values, they bear repeating, I believe.
/ /
- 1/
./~The first is Witmaver v. Witmaver, 467 A.2d 371 (1983) which stands for the
C_prbposition that siblings, even half siblings, should be raised together unless there are
compelling reasons to do otherwise. The Witmaver Court made this determination even
1'1 the cas!'! where there W8" fl sel/en-yp.ar clitferencp, h"ilwp.p.n the R!JPR nf the chilrlrp.n
Although the Court may, of course, give positive consideration to the parent
whose function is primary caregiver, Mr. Lander asserts that up until April, 2000, that
function had been shared. He relies on the best interest of the child standard,
repeatedly enunciated, as placing on the Court's burden of determining "which parent
will best serve the physical, intellectual, spiritual and moral wellbeing of the children."
McAllister v. McAllister, 747 A.2d 390 (2000). Mr. Lander respectfully submits that the
evidence at least at the hearing indicates that he can best serve his child's physical and
intellectual needs as evidenced by his attention to her homework and extra curricular
activities, and that her spiritual and moral wellbeing would be served by residence with
him and the child's extended family in the Pittsburgh area.
The Honorable Edgar B. Bayloy
March 22, 2001
Page 2
I realize that I am not bringing to the Court's attention anything of which it was not
aware, but in this case, the issues are decided by a matter of emphasis, I believe.
Thank you very much for this opportunity.
Very truly yours,
WER & LINDSAY. P.C,
)
CJUljb
cc: Leonard Lander
Jeffrey S. Shank. Esquire
GINGRICH, SMITH, K'.INGENSMITH & DOLAN
.ATTorHH:'I'~ AT LAW
"2.! ~.OUTli MAUI([T ~,urrt, ',IJlT' ~'()I
f1 0 no~ ."P
ELIZABCTHTOWN, PA 1102Z-0267
!117l 367-1370
'-A. 11111 .)(\7 ;1,,'10
,JOHN M SMITH
THOMAS G KI.INGENSMITH
KeVIN 0 DOl....H
HER.ERT P HENDERSON, II
.J1t""AEY 5 SHANK
JOANNE MURPHY
"'... t:",,,\I nr..~(~'. ~.".,.,.,
LA....CA5Tcrf, PA 17602
17111 ;)Q:J'36H4
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W.t> S,'_ WWWOSI'lOLA.....COM
0' CO\J"'.IH
HeNRY F" GINGRICH
March 7,2001
Honorable Edgar B. Bayley, Judge
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013-3387
RE: Marvella L. Lander vs. Leonard G. Lander, Jr.
No. 98-5746 Action in Custody
Dear Judge Bayley:
Enclosed please find a courtesy copy of the Pre-Trial Statement of Plaintiff for March 21,
2001 Hearing in connection with the above-captioned maller which has been or will be filed in the
Prothonotary's Office.
Thank you for your kind attention to the above.
Very truly yours,
GINGRICH, SMITH, KLINGENSMITH & DOLAN
JSS:tmr
enclosure
pc: Ms. Marvetta L. Lander
Carol J. Lindsay, Esquire (with enclosure)
the subject minor child.
Mother is originally from Kansas. She moved to Pennsylvania only to be with Father.
Mother has no family in Central Pennsylvania and docs not feel attached to Pennsylvania. She is
requesting to relocate to Kansas with Rachel at the end of this academic year.
Dr. Arnold Sheinvold did a custody evaluation. He is scheduled to testify on behalf of
Mother. The parties received Dr. Sheinvold's written report on or about December 20, 2000.
Mother is requesting Father pay at least one-half(Y.z) of Dr. Sheinvold's appearance fee of$600.00.
Mother paid the entire fee to ensure Dr. Sheinvold's appearance. Father was responsible to pay for
sixty-five (65%) percent of the evaluation. Mother was responsible to pay for thirty-five (35%)
percent of the evaluation.
Dr. Sheinvold in his written report is recommending that Rachel remain in the primary
custody of her Mother. Dr. Sheinvold acknowledges there is substantial depth to the emolional
attachment Rachel has with Mother. Dr. Sheinvold evaluated Rachel moving to either Western
Pennsylvania or with Mother to Kansas. He concluded it would be unfair to block Mother from
making a move to a location that she finds supportive and replete with new job possibilities when
Father moved for very similar reasons. Dr. Sheinvold provides in his written report that he does not
believe Mother's move to Kansas would destroy Father's relationship with Rachel. Dr. Sheinvold
will testify, based upon his written report, that if the Court allows Mother to move, he is
recommending Rachel have substantial partial physical custody with her Father during the Summer
and at other times so as not to interfere with school.
Mother will testify she has been the primary parent since Rachel's birth, will acknowledge
a brief period of depression resulting in an inpatient hospitalization at the Carlisle Hospital in 1995
followed by out-patient treatment at the Harrisburg Institute of Psychiatry for approximately four-
five weeks. She will testify she is not currently taking anti-depression medication and there is no
recommendation for ongoing treatment of her at this time. She has not been on medication for
approximately two years.
Mother will testify she has been gainfully employed at Right Aid as a field-system analysl
since March 1998. Prior to that time she will testify that she worked for the American Trauma
Society. She will testify she stayed at home with Rachel until she was approximately 3Y, years old.
Rachel is currently 11.
Mother will testify in her opinion Rachel is more bonded to her than to her Father. Mother
will testify Rachel does not do very well in school because she dislikes school and that, as a result,
Mother consults with and attends meetings with the instructional support team. Father does not
participate in such meetings. Mother will testify the subject minor child counseled with Ms. Nancy
2
(, .,;
Small and the counseling was provided to assist Rachel in dealing with the separation of her Mother
and Father.
Mother will testify she has concerns with Father's anger and will testify to specific instances
with respect to the above.
As indicated at the custody conference, and as referenced in this Court's Order of August 25,
2000, Mother does desire to relocate to Kansas with her family. The custody evaluation took into
consideration Mother's request.
Mother will testify ifpennitted to relocate to Kansas with Rachel, they will reside with her
mother in a three bedroom house. Mother will testify it is her plan to attend school to become a
Microsoft certified computer engineer. Mother has three sisters all located within the area of Kansas
in which Mother intends to relocate. Mother has a number of nieces and nephews in Kansas.
Mother desires the support system her family can provide. Rachel will attend the Desoto School
District. Desoto is a fast growing school district. The district recently constructed new buildings
and facilities. Mother and Rachel were last to Kansas City in Summer 2000. They go to Kansas to
see her family two (2) weeks out of every year. Mother will testify she, in essence, has always
wanted to move back. She believes it is in Rachel's best interest to now get to know her family and
have available their support for her.
Mother may call as a witness Mrs. Cook, Principal of the Shiremanstown Elementary School
with respect to the best interest of Rachel. Mother may call as a witness Ms. Sharon Peterman, a
personal friend of Mother, with regard to matters involving the best interest of Rachel. The subject
minor child, Rachel, will be available at the hearing on March 21, 2001.
Respectfully submitted,
Date: 3/..,/; I
GINGRICH, S~ITH, KLINGENSMITH & DOLAN
Iv
effrey S. Shank, Esquire, ill #74471
Attorney for Plaintiff
222 South Market Street, Suite 201
Elizabethtown, P A 17022
(717)367-1370
3
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IN THE COURT OF COMMON FtEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION
MARVETTA L. LANDER,
Plaintiff
vs
)
)
)
)
)
)
)
No. 98-5746 - Civil Tenll
LEONARD G. LANDER, JR.,
Defendant
CERTIFICATE OF SERVICE
I, Jeffrey S. Shank, Esquire of Gingrich, Smith, Klingcnsmith & Dolan, Attorney for the
above-named Plaintiff, hereby ccrtify that I duly served a copy ofthc foregoing Pre-Trial Statement
for Plaintiff onto the following at the following address by United States first-class mail:
Honorable Edgar B. Bayley, Judge
Cumberland County Courthouse
I Courthouse Square
Carlisle, PAl 7013.3387
Carol J. Lindsay, Esquire
26 West High Street
Carlisle, PA 17013
Respectfully submitted,
GINGRICH, SMITH, KLINGENSMITH & DOLAN
Date: 3/";;), /
~
effrey S. Shank, Esquire, ill #74471
Attorney for Plaintiff
222 South Market Street, Suite 201
Elizabethtown, PAl 7022
(717) 367-1370
4
schedule permitted him nearly fifty (50%) percent of his child's time without depriving
Mother of child support, Father will also testify that it was his judgment althe time of
separation, and it continues 10 be his judgment, that his ongoing contact with his
daughter was necessary to provide the stability, educational support and emotional
support which the child required given the tumultuous response of Mother to the
separation.
In April 2000, Father was reassigned to the Pittsburgh area in an under cover
unit. He filed a Petition for modification of the Custody Order seeking primary physical
custody of the child in light of his move. Mother responded with her own request for
relocation, this time to Kansas City.
The parties engaged in a custody evaluation. The evaluator recommended
that Mother be permitted to move and that the child move with her. Father opposes
the move and believes that the evaluator failed to take into account his legitimate
concerns about the effect on the child of her living with Mother without his ongoing and
direct involvement.
II. WITNESSES:
Father will present the following witnesses:
1. Leonard G. Lander, Jr.. father. who will testify regarding his experience
with his daughter. his ability to care for her and his concerns for her in the event that
Mother is permitted to remove to Kansas City.
2. Sally Worst, who is a Pennsylvania State Trooper and the fiancee' of
Leonard Lander. She will testify regarding her relationship with the child and her
observations of the child in the custody of Father as well as her experiences with
Marvetta Lander.
3. Marilyn Lander, who is the maternal grandmother of the child. She will
testify regarding her experience with her granddaughter and the relationship between
Father and child.
Respectfully submitted,
SAlOIS, SHUFF, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By: !(l.(!LfO I ,J L/id:5Ct (["
Carol J. Lindsay, Esqui
ID# 44693
26 West High Street
Carlisle, PA 17013
(717) 243-6222
MARVETTA L. LANDER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 98 - 5746 CIVIL TERM
: IN DIVORCE
vs.
LEONARD G. LANDER, JR.,
Defendant
CERTIFICATE OF SERVICE
AND now, this /5 day of I'Y? 1<. ( ( 1,,- , 2001, I, Carol J.
Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, hereby
certify that I served the within Defendant's Pre-trial Statement this day by depositing
same in the United States Mail, First Class, Postage Prepaid, in Carlisle,
Pennsylvania, addressed to:
Jeffrey S. Shank, Esquire
GINGRICH, SMITH, KLINGENSMITH & DOLAN
222 South Market Street, Suite 201
P. O. Box 267
Elizabethtown, PA 17022-0267
SAlOIS, SHUFF, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
{{",_1.VJMa f /uJ-{iuJ
Carol J. Lindsay, Esquire
10# 44693
26 West High Street
Carlisle, PA 17013
(717) 243.6222
MARVETTA L. LANDER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
LEONARD G. LANDER, JR.,
DEFENDANT
: 98-5746 CIVIL TERM
IN RE: CUSTODY
ORDER OF COURT
AND NOW, this -Zq ""'day of March, 2000, IT IS ORDERED:
(1) All prior custody orders are vacated and replaced with this order,
(2) Marvetta L. Lander and Leonard G. Lander, Jr., shall have shared legal
custody of Rachel M. Lander, born November 27, 1989.
(3) The mother shall have primary physical custody of Rachel.
(4) The petition of the mother to move Rachel to Kansas City, Kansas, IS
DENIED.
(5) The father shall have temporary physical custody of Rachel:
(a) During each four-week segment of the school year, three out of four
weekends from Friday after school until Sunday evening at 8:00 p.m., but
if Monday is a school holiday then until Monday at 8:00 p.m. Two of these
weekends shall be on the weekends the mother is working. The third
weekend shall be agreed upon by the parents at least one week in
advance.
(b) During the summer vacation period, starting on the first Sunday for
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98-5746 CIVIL TERM
assigned to Troop H in Carlisle, Cumberland County, where the mother and Rachel
joined him. The father worked midnight shifts for three years. In mid-1993, the mother
started working outside of the home. In the latter part of 1997, and the beginning of
1998, the mother took a nine-month course in computer training.
The parents were immature when they married. Their relationship was volatile
throughout. The mother had episodes of depression, which resulted in her
hospitalization in 1995. She responded well to medication and was transferred to a
partial treatment program and then an outpatient program from which she was
discharged. She shows no signs of depression now and is functioning well. She has
worked for Rite Aid Corporation for three years. She works every Monday, Tuesday,
Wednesday, and Friday from 8:15 a.m. to 5:15 p.m. She is off work every Thursday.
She works every other weekend on Saturday and Sunday from 8:15 a.m. until 5:15 p.m.
The mother lives in an apartment in Mechanicsburg, with Rachel and her boyfriend
Charles Lorenz, age 24. She met Lorenz in October, 2000, and started living with him
in November. Lorenz works for a company that selVices properties that have been
damaged by fire. He is the second man the mother has lived with since she separated
from husband.
The father worked patrol and criminal investigation. In 1999, he applied to make
a career change within the state police. Although he hoped to be able to work in
Harrisburg, on April 1 , 2000, he took an assignment in Pittsburgh, where he works as
an undercover drug enforcement officer. This change did not result in an increase in
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98.5746 CIVIL TERM
salary. The father now mostly works from 10:00 a.m. to 6:00 p.m. Monday through
Friday. He and his girlfriend, Sally Worst, age 31, a Pennsylvania State Officer
stationed at Troop H in Carlisle, had lived together in Carlisle. They have a daughter,
Kaitlyn, who is one-year-old. Worst bought a house in Irwin in August, 2000, into which
the father moved. Worst and Kaitlyn will be joining him at the beginning of April, 2001,
as she has obtained a reassignment to the Greensboro barracks of the Pennsylvania
State Police. She and the father plan to marry. The father's parents, a brother with
children ages 4 and 2, and some aunts and uncles all live close to his new residence.
Rachel knows this family well.
When the father was living in Carlisle, he had Rachel under a court order on
alternate weekends, on Monday evenings, on Wednesday evenings overnight, and
every Thursday evening overnight. He also saw her for extra periods. After he moved
to Irwin in the beginning of April, 2000, he has Rachel under a court order for three out
of every four weekends. During each school week, the mother now takes Rachel to a
bus stop each school day morning. After school, Rachel goes to a babysitter between
3:30 until the mother picks her up after work.
That babysitter has a job at night. She has the mother baby-sit her son at night.
That boy arrives at the mother's at about 9:00 p.m. and stays there the entire night.
Rachel's bedtime is 10:00 p.m. The mother testified that Rachel does most of her
homework at the babysitter's. Usually she completes it there. If not, the mother stated
that she always makes sure that it is finished. She testified that Rachel does not like toi-3-
96-5746 CIVIL TERM
read and that it is difficult to get her to read, although she is improving. She testified
that sometimes she makes Rachel dinner at home, and then she will play. Sometimes
they go out to eat, then shop or go to the movies or do some other activity together.
The maternal grandmother and grandfather are separated. They live in Kansas
City as does the mother's two sisters. The mother was abused by her father when she
was a child and she has little contact with him. The mother had a difficult relationship
with her mother who was cold, aloof and distant. She testified that her mother regrets
her past conduct and is making amends. She and her mother have now become
closer.
The mother has two sisters who live near the maternal grandmother's house in
Kansas City. The mother has always gotten along well with the younger sister, who has
a boy age 11, but had difficulties with her older sister, who has a boy age 14. They now
have become closer. The mother testified that she wants to move with Rachel into her
mother's three-bedroom home in Kansas City. Her mother works two full-time jobs.
The mother testified that she wants to go to school full-time to become a Microsoft
certified systems engineer. She would not be working while in school. She testified
that a younger sister, who does not work outside of the home, will provide babysitting
services for Rachel when she is not in school. She stated that she has looked into
schools for Rachel in Kansas City, and has found the DiSoto Middle School. It is
outside of the school district in which her mother lives, but Rachel could attend there to
receive the special attention for her ADD type problems. The mother did not provide
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98-5746 CIVIL TERM
any specifics as to what school she wants to attend to become a systems engineer, and
how long such a program willlas!. Nor did she present any evidence as to the
difference such additional training would make with regard to any prospective
employment versus what her employment circumstances are now. The mother testified
that her mother will not charge her ren!. She believes that she can improve herself in
Kansas, and that living with her mother with the rest of their family nearby will provide
her a support system that she does not have now. Rachel knows her maternal
grandmother, her two aunts, and her cousins well. Charles Lorenz testified that he will
not go to Kansas City with the mother.
Arnold Shienvold, Ph.D. a clinical psychologist, conducted a custody evaluation.
He found that Rachel was a high-energy, assertive child. While not being specifically
diagnosed with attention deficit disorder, she has many of the attributes of that
condition. Her physician has prescribed Ritalin, which she takes in school. She takes
Prozac on weekends. Rachel is defiant at times because of her attention problem. Dr.
Shienvold testified that she is a nice child, who needs attention to keep her focused.
She makes friends well, has good social skills, but has academic difficulties. Rachel is
now in the fifth grade. Her performance has declined during this school year. She is
followed by a coordination team at her elementary school that fashions the most
advantageous program to help her with her difficulties. The school plan states, and Dr.
Shienvold agrees, that Rachel needs close supervision, structure, and parental
involvement in the home.
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98-5746 CIVIL TERM
The mother testified that Rachel is very open and truthful with her. She
acknowledges that she loves her father. The mother believes that he is a good father
except that he gets angry with Rachel and occasionally physically disciplines her. The
mother does not practice physical discipline. The father testified that he occasionally,
mildly physically disciplines Rachel.
Dr. Shienvold believes that Rachel is clearly more bonded emotionally to her
mother than her father. While he stated that this bond has some unhealthy
characteristics based on some acts of bad judgment on the part of the mother, on
balance it is a healthy, loving relationship. Rachel has been sleeping with her mother
during periods of when the mother did not have a boyfriend living with her. She now
sleeps in her own bed. At times the mother has involved Rachel directly in her conflict
with the father. At times her conduct with Rachel is too adult in sharing inappropriate
information with her. Living with men on a temporary basis is not in Rachel's best
interest. '
Dr. Shienvold testified that if Rachel had a choice, she would rather have the
current situation continue. If not, she would rather go to Kansas City with her mother
'When the mother and Rachel were visiting in Kansas last summer, Rachel got
undressed along with her male cousin who then got on top of her. Later, the same
thing happened with her other male cousin. On both occasions the children were
watching a movie. The mother and her sisters were in the house. When they learned
what happened the mother immediately called the father. They had a social worker
intervene and when Rachel came home she undertook some counseling. The father
and mother agree that they both handled this situation in a responsible manner.
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98-5746 CIVIL TERM
than live with her father and Sally Worst in Irwin. In chambers, Rachel appeared to be
a "young" eleven-year-old. She told us that she likes being with her father, but wants to
live with her mother. Dr. Shienvold believes that Rachel has been negatively effected
by the substantial conflict between her parents. She received social service counseling
for a year fOllowing their separation. Rachel initially had ambivalent feelings about Sally
Worst, but their relationship has improved. She loves her mother and father and they
are both capable of caring for her. Dr. Shienvold believes it is in the best interest of
Rachel that she live with her mother, but have substantial contact with her father. He
recognized that if Rachel moves to Kansas City, that contact will be different than it
currently is, but it should be as extensive as possible, including an eight week period
during the summer. Dr. Shienvold concluded that the father's move to Pittsburgh
negatively impacted on Rachel. While the current custody schedule still gives him
considerable time with her, he is no longer a daily part of her life.
A determination of a child's best interest is on a case-by-case basis, and is to be
premised upon consideration of all factors that legitimately affect the child's physical,
intellectual, moral and spiritual wellbeing. Alfred v. Braxton, 442 Pa. Super. 381
(1995). In forging a relationship with Sally Worst, the father has stabilized his life to a
greater extent than the mother. Yet, despite fully recognizing Rachel's need for
stability. he moved to Irwin for his own career. Now, when the mother seeks to move
Rachel to Kansas, he seeks primary custody. While he has maintained a good
relationship with Rachel on a regular basis, her traveling back and forth over the
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98-5746 CIVIL TERM
specific goals. Her petition to move Rachel to Kansas seems to be in response to the
father's actions rather than a result of a thoroughly thought out plan designed to
significantly improve the quality of life for her and her daughter. While the mother has
stayed in contact with her family over the years it has not all been smooth sailing. We
believe that moving Rachel to Kansas would substantially change her relationship with
her father. While his opposition to the move is weakened by his own conduct,
notwithstanding, given the current situation and his strong desire to be an integral part
of Rachel's life, satisfies us that his motives are sound in opposing his daughter moving
to Kansas. The relationship he could maintain with her if she moved would hardly be
the significant ongoing contact that he now has which is very beneficial to Rachel. It is
also good for Rachel to have steady contact with her lillle sister, Kaitlyn. Given all of
the evidence, we are satisfied that the mother should not be allowed to now move
Rachel to Kansas.
For the foregoing reasons the following order is entered.
ORDER OF COURT
AND NOW, this '1. Of, 4- day of March, 2000, IT IS ORDERED:
(1) All prior custody orders are vacated and replaced with this order.
(2) Marvelta L. Lander and Leonard G. Lander, Jr., shall have shared legal
custody of Rachel M. Lander, born November 27, 1989.
(3) The mother shall have primary physical custody of Rachel.
(4) The petition of the mother to move Rachel to Kansas City, Kansas, IS
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98.5746 CIVIL TERM
DENIED.
(5) The father shall have temporary physical custody of Rachel:
(a) During each four-week segment of the school year, three out of four
weekends from Friday after school until Sunday evening at 8:00 p.m., but
if Monday is a school holiday then until Monday at 8:00 p.m. Two of these
weekends shall be on the weekends the mother is working. The third
weekend shall be agreed upon by the parents at least one week in
advance.
(b) During the summer vacation period, starting on the first Sunday for
three continuous weeks. Rachel shall then spend three continuous weeks
with her mother after which the father shall have her for another three
continuous weeks.
(c) Each December 271h until January 1st. The mother shall always have
Rachel for the first part of the Christmas school vacation until December
271h.
(6) The father shall provide all transportation for his periods of temporary
physical custody.
(7) When each parent has Rachel that parent shall provide her with reasonable
telephone access to the other parent.
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98-5746 CIVIL TERM
By the Court, ? I
Jeffrey S. Shank, Esquire
For Plaintiff
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Edgar B. Bayley, J. ~
Carol J. Lindsay, Esquire
For Defendant
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MARv.:nA I. I.AND.:R.
I'lillIlI,ITiPclllllln,'r
IN TIlt: COllRT (n' COMMON I'U:AS Of'
C1Jl\lIlt:RI.ANIl COUNTY. P.:NNSYI.VANIA
CIVIl. ACTION. IlIVORn:
VS.
U:ONAIUl G. I.A:'HH:Il. .lIl.
IlefelldilllllRClI"JIIdcnl
NO. 19'IH.~74(. CIVIl. n:IlM
IN IlIVORn:
D R# 2H9H~
P.ucllll J041t114H6
ORn.:R
AND NOW. 10 wit, on this 25" day of June, 2002 IT IS HERBY ORDERED that the alimony
pendente lite order in Ihis case be terminated wilhout prejudice efTeetive February 1.2001. due to
the January 19,2001 stipulation of Ihe parties and an alimony award being entered,
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BY THE COURT:
DRO: RJ Shadday
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ORUFR/NOTlcr TO WlTlillOW INCOME FOR SUPPORT
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ATTACHMENTS RESEARCH UNI'r
PO BOX 8006
HARRISBURG PA 17105-8006
176-62-1890
I 'lIplrl\I'I':t Ibllgor', "'0. 1,lt ""'1 wdl N(,ml~',
9701100108
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See Addendum for dependent n.lmes .md birth d.l/es associated with c.lses 011 .llt.lchment.
ORDER INFORMA nON: Thb i,.1n OrcIN/NOli,!' 10 IVilhhold InlOm!' for SlIpporl h.l",d lIpon .In ordN for,"poort
(rom CUMBERLAND County, Commonwt',lllh of Ppnnloylvdnid. By l,lw, you .!r(l H'<!uired to (h,'durf these
amounts from the dhove-ndowd pmploypp\/ohliglJr's income until furtlwr nOlin' ('vpn ii Ihp Onlt'r/Nolin' is not
issued by YOllr 5'''11'.
$ 1.079.00 per month in ("urrflnt support
$ 20.00 per month in pdsl.due support Arrp.J(s 12 w('('ks or W('dfpr? 0 Yt's ~ no
$ 0,00 per month in nwdicdl support
$ 0.00 per month for grnellf Ipsl costs
$ 1"" monlh in olher (sp!'dfy)
for a lolal of $ 1,099.00 per month 10 be forwarded to payee below.
You do nol have 10 Vilry YOllr p"y cycle 10 be in compli.lnce with Ihe '"pport order. If YOllr p"y cycle do", nol match
the ordered support payment cycle, u,e Ihe following 10 dl'l!'rminl' how mllch 10 wilhhold;
$ 253.62 per weekly pay period,
$ 507.23 per biweekly pay period (I'very Iwo week,).
$ 549.50 per semimonlhly P.1Y pl'liod tlwice a monlh>.
$ 1.099.00 per monthly pay period.
REMITTANCE INFORMA TlON:
You musl begin wllhholding no laler Ihan Ihe first pay period occurring len (10) working dilYs "fler the dale of Ihis
Order/Nolice. Send paymenl within ,even (7) working days of the p"yda'e/d,,'e of wilhholding. You are enlitled to
deducI a fee to defray the cost of wilhholding. Refer 10 Ihe laws governing Ihe work "0111' of your employee for Ihe
Ihe allowable amounl. The 101.11 wilhheld amounl, and your fee, cannol exceed 55% of Ihe I'mployee'sf obligor's
aggregate disposable weekly earnings. For Ihe purpose of Ihe limilalion on withholding. the following information is
needed (See #9 on pg. 2).
If remitling by EFT/EDI, please call Pennsylvania Slale Colleclions and Disburseml'nl Unil (SCDU) Employer
Customer Service aI1-877-676-9580 for inslruclions.
Make Remittance Payable to: PA SCDU
Send check to: Pennsylvania SCDU, P,O. Box 69112, Harrisburg, Pa 17106.9112
IN ADDITION, PA YMENTS MUST INCLUDE THE DEFENDANT'S NAME AND THE PACSES MEMBER ID (shown
above as the Emptoyee/Obligor's Case Identifier) OR SOCIAL SECURITY NUMBER IN ORDER TO BE PROCESSED.
DO NOT SEND CASH BY MAIL.
BY THE COURT:
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Date of Order: JUN 2 : 2002
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Form EN-028
Worker ID $IATT
A[}()JTIONAlINrORMAlION 10 rMPIOYlR~ ANll OlltlR WlllflIOLllIK~
o II (hl'( ~l'fl "fill .H1'"'IIUlrl'fIIU 11'0\'11/1'.1 C lIp~ IJlllm fWlIllo \IIW 1'11I1'111\1'1'
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.IKI'ne V 'I'h"lllll'low.
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.1.' Rf.'t()r1in~ lh<<. P.I)'tfi1II'/l>,lfl' fit Wtlhh(lldrlll~~ You nUl...1 rl'Jlflr1lh,' fIolVd.I/f'/cI.III' 01 \\'llhholdm,: wlll'1l "'1',ujHl~ Ihl' p"ymr'nl. Thr
payd;lIr/dalr of withholdin~ ''I Ihl' 11.111' on whll h amount \\',1" Wllhllf'ld 'rom thr' ,'",pIIlVI'f"" \\,.1':1''', You 11I11.,11 omply wilh tlu' lei..... of th('
~1.lh' of th,' ('J1lIJl()y"("..!ohli~or'" pruHlp.11 pl.le I' or l'fllplo\'IlH'1I1 WIth 11....111'1110 Ihl'liml' IH'fIlHI" \\ ilhm willi" you mu..' imph'lIlt'fll Ill('
withholding md('r .md iOr\\'.mllhl' "upporl p,lyr'H'llh.
4.' Employ('('/Obligor with ~'ullipl(' SUPPor1llnldin.:..: Ii lht'u' '" IllCUP Ih,HlIllll' ()rlll'r/N(llin' 10 \Vilhllllld In(on1l';or Support
ilg.linst this ('mploy(,t'!ouligor .mil YOU.HP un.lllll' 10 honor ,Itl ..uppor1 ()nIN/Nolil 1''' dul' 10 Il.dl'r.11 or Slotlt' wilhholding lil11it~, you musl
follow Ih(' 1.1W of th(' 51.11(' of I'mploYPI"../ohligor... Jlrill(ip.llpl.UI' of I'fIlJlIO~'IlH'nl. You Ilw..1 honor .111 ()n:t'r'l/Notkp'o 10 Ill(' gf('al('..1
extent possible. (Set' #9 helow)
5. Tcrminiltion NOlijica!ioll: You musl promplly noli;y Ih" RI'IJIJl...'ing AgPllc}' wllt'n Iltl'l'lIll1ll1V('C','lIlJligor i.. (to /(JfI~('r working jor
you. P/('Jse provide the inform.1lion f('(luPSlecl .m(1 rl'lurn.1 (111'Y olllli.. ()rtll'r/N()lin'lllllll' Ag('fl(Y ill('nlifif'(II)('I()w.
WITHHOLDER'S ID: 2321722990
EMPLOYEE'S/OBl/GOR'S NAME: LANDER, LEONARD G. JR
EMPLOYEE'S CASE IDENTIfiER: 9701100108 DAn or S(f'ARAIION:
LAST KNOWN HOME ADDRESS:
NEW EMPLOYER'S N,\MEh\DDRESS:
6. lump Sum Polymenllt: You nMY be requir('d 10 rl'por1 .m!! wilhholcl from IUtl1p..Wll p.IYflwnt.. ..uch .1'0 honus('~, commissions, or
sever.mee IMY. If you have any queslions ,l!Joullump sum p.l~'IIH'nt.., (onl.l(lll1(' Jll'rson or oIulhorily In'low.
7. liabilily: If you fail 10 withhold income .1S Ihe Order/Nolie(' dirf'Cls, YOll ,u(' Ii.llllf' for both lh(' .ICCUlT1ul.lled .mlOunl you should
have withheld from the employee/ohligor's income ilnd otlll'r p(ln,llti(>s '1('1 by P('nnsylv.mia Sidle I,IW. Pennsylvania Slale law governs
unless the ohligor is employed in anolher Slale. in which C.15(1lhl' I,l\\, of 11ll' Stale in which IH' or 'lIlt' i~ I'rnployC'd governs,
8. Anti.discriminalion: You .Ire suujecllo .llinl' detl'rrnil1pd IIndt'r 5t.lIp ldw lor disch,Hging ,Jrl employel'/ohligor from
employmenl, refusing 10 employ, or I.lking disciplinMY .lClioll ag,limt ilny l'mploy('('/ohligor hcctlus(' oi ,1 ~upport wilhholding.
Pennsylvania Slale law governs unless the obligor is ('mploYi'd in .lnollwr 51"1(', in which ("I~e the law of 111(' SI.lte in which he or she is
employed governs.
9.. Withholding limits: You may nol withhold more Ihan the lesser of: 1) Ihe amounts allowed by the Federal Consumer Credit
Protection Act (15 U.S.c. 91673 (b)l; or 2) the amounts allowed by the Stale 0; the {'mploy('e's/obligor'~ prinrip,ll plan' of employment.
The Federal limit applies to the aggregate dispos<llllc weekly earnings ("OWE). ADWE is Ihe net income lefl after making mandalory
deductions such as: Slale, Federal, local taxes; Social Security laxc5; .md Medicare IdX('S.
10.
. NOTE: If you or your agenl are served wilh ,\ copy of this order in the stale that issued the order, you are to follow the
law of the state that issued this order with respect to thcsp ilems.
Requesting Agency;
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST
P.O, BOX 320
CARLISLE PA 17013
If you or your employee/obligor have any questions.
contact WAGE ATTACHMENT UNIT
by telpphone al (7171 240-6225 or
by FAX '" (717) 240-6248 or
hy Inlernet @
Service Type M
Pdgl' 2 of 2
Form EN-Om
Worker ID $IATT
o'\IUNu (J'),'(I,l/l'i4
l'l'jr.,tinll O.,r,'.llIll/IK]
landor --- politlon for roconsidoralion (Ordor of Court) Juno;> t. ;>00;>
MARVETTA L. LANDER,
Plalnllff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98 - 5746 CIVIL TERM
vs.
LEONARD G. LANDER, JR.,
Dofandant
IN DIVORCE
ORDER OF COURT
AND NOW this
.sA
day of
}vt
-........
, 2002,
upon consideration of the within Stipulation of the Parties, the terms of said
Stipulation are hereby entered as an Order of Court,
By the Court,
-/
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J.
SAIDIS
SHUFF. FLOWER
& LINDSAY
A1TORNEVSoAToL\W
26 W. HIgh Streel
Carlisle, PA
landor ... potition for roconsidoralion (Ordor or Court) Juno 21. 2002
MARVETTA L. LANDER,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98 - 5746 CIVIL TERM
Plalnllff
vs.
LEONARD G. LANDER, JR.,
Defendanl
IN DIVORCE
STIPULATION OF THE PARTIES
1. The parties hereto entered into an Agreement in the Office of the
Divorce Master on Friday, January 19, 2001.
2. With regard to alimony, the parties agreed that for a period of two years
commending February 1, 2001, Husband would pay Wife alimony in the amount of
$250.00 per month, which alimony would not be modifiable except on the death of a
party and specifically not modifiable in the event of Wife's cohabitation or her
remarriage.
3. Paragraph 9 of the Agreement included the commencement date for
the alimony but not the termination date.
4. By the terms of the parties' Agreement, alimony terminates on January
31,2003.
SAIDIS
SHUFF, FLOWER
& LINDSAY
5. The parties intend to amend their Agreement of January 19, 2001
^1TORNtYS.AT.L.\W
accordingly, which amendment can be entered as an Order of Court.
26 W. IIIgh Street
Carlisle, PA
~-./~~
Leonard G. Lanaer, Jr.
~/2{!7.fh '-If /7ri f/)
Marv tta L. Lander
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Date
0lA( 2, ?On2
--='/ Date
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SAIDIS
SHUFF, FLOWER
& LINDSAY
^TroRNEYS.AToL.\W
26 W. High Street
Carlisle, PA
landor on petlllon for roronsidorahon (Ordor 01 Court) Octolmr 2~), 2002
MARVETTA L. LANDER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plalntlfl
vs.
CIVIL ACTION - LAW
NO. 98 - 5746 CIVIL TERM
IN DIVORCE
LEONARD G. LANDER, JR.,
Defendanl
AND NOW this
ORDER OF COURT ~
\3. day of
,
,2002,
upon consideration of the wilhin Stipulation of the Parties, the terms of said
Stipulation are hereby enlered as an Order of Court.
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By the Court, / /
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SAIDIS
SHUFF, FLOWER
& LINDSAY
^TIURNEVSoAToLt\W
26 W. High Street
Carlisle. PA
landor ... pe,,'ion for reconsideralion (ardor 01 Court) Oclobor 25. 2002
MARVETTA L. LANDER,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 90 - 5746 CIVIL TERM
IN DIVORCE
Plalnliff
vs.
LEONARD G. LANDER, JR.,
Defendant
STlPULA TlON OF THE PARTIES
The parties hereto stipulate as follows:
1. They are the parents of Rachel M. Lander, born November 27, 1989.
2. Custody of Rachel is governed by the Court's Order of March 29, 2000
to the above caption.
3. On or about June 24, 2002, Leonard G. Lander, Jr., hereinafter Father,
filed a Petition for Contempt. The matter was set for conciliation on July 24, 2002
and then for a hearing before the Court on October 2, 2002.
4. The parties have agreed to continue the Court hearing in anticipation of
the filing of this Stipulation and its entry as an Order of Court.
5. Mother will provide to Father an additional weekend with Rachel on
November 15, 2002. For that period of partial custody, Mother will drive the child to
the Bedford Interchange of the Pennsylvania Turnpike where Father shall meet her
and the exchange of custody shall take place at that time. On Sunday, the parties
shall meet at the Breezewood Interchange for the transfer of custody back to Mother.
6.
In the event that Father in the future files a Petition for Contempt, he
may offer testimony with regard to Mother's acts alleged in the Petition he filed on
June 24, 2002. However, he will be deemed to have received any compensatory
time resulting from the acts Father alleged in the Petition he filed in June 2002.