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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEBORAH L, ZEPP,
Plaintiff
v.
NO. tHJ - '7<:.902 ~ '[;p-
JOHN C. ZEPP, III.,
Defendant
CIVIL ACTION - LAW
DIVORCE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling. A
list of marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Courthouse, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
DIANE G, RADCLIFF
3448 TRlNDLE ROAD
CAMP HILL, P A 17011
(717) 737-0100
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEBORAH L. ZEPP,
Plaintiff
v.
NO. 1J7). J&tf.z ~ T___
CIVIL ACTION - LAW
DIVORCE
JOHN C. ZEPP, III.,
Defendant
COMPLAINT
AND NOW, thiS~ay of October, 2000, comes the Plaintiff,
DEBORAH L. ZEPP, by her attorney, DIANE G. RADCLIFF, ESQUIRE, and
files this Complaint in Divorce of which the following is a
statement:
COUNT I: DIVORCE
1. The Plaintiff is DEBORAH L. ZEPP, an adult individual residing
at 121 State Street, York Springs, PA 17372.
2. The Defendant is JOHN C. ZEPP, III" an adult individual
residing at P. O. Box 204, York Springs, PA J7372.
3. Plaintiff and/or Defendant have been bona fide residents of
the Commonwealth for at least six (6) months previous to the
filing of this Complaint,
4. Plaintiff and Defendant were married on June 8, 1974 at York
Springs, Pennsylvania.
5. There have been no prior actions of divorce or annulment
between the parties.
6. Plaintiff has been advised of the availability of counseling
and the right to request that the Court require the parties to
participate in counseling.
DIANE G, RADCLIFF
3448 TRINDLE ROAD
CAMP HILL, P A 170 II
(717) 737.0100
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DIANE G, RADCLIFF
3448 TRlNDLE ROAD
CAMP HILL, PA 17011
(7] 7) 737-0]00
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7. The Defendant is not a member of the Armed Services of the
United States or any of its Allies.
8. The Plaintiff avers that the grounds on which the action is
based are:
a. That the marriage is irretrievably broken;
Or in the alternative,
b, That the parties are now living separate and apart, and
at the appropriate time, Plaintiff will submit an
Affidavit alleging that the parties have lived separate
and apart for at least two (2) years and that the
marriage is irretrievably broken.
Or in the alternative,
c. That Defendant has offered such indignities to the person
of the Plaintiff, the innocent and injured spouse, as to
render her condition intolerable and life burdensome, and
that this action is not collusive.
, WHEREFORE, Plaintiff requests this Honorable Court to enter a
decree in divorce, divorcing the Plaintiff and Defendant.
COUNT II: EOUITABLE DISTRIBUTION
9. Paragraphs 1 through 8 are incorporated by reference hereto as
fully as though the same were set forth at length.
10, Plaintiff and Defendant have acquired property and debts, both
real and personal, during their marriage from June 8, 1974
until April 10, 1999, the date of separation, all of which are
"marital property" or "marital debts".
11. Plaintiff and/or Defendant have acquired, prior to the
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DIANE G, RADCLIFF
3448 TRlNDLE ROAD
CAMP HILL, P A 17011
(717) 737-0100
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marriage or subsequent thereto, "non-marital property" which
has increased in value since the date of marriage and/or
subsequent to its acquisition during the marriage, which
increase in value is "marital property".
12. Plaintiff and Defendant have been unable to agree as to an
equitable division of said property and debts as of the date
of the filing of this Complaint.
WHEREFORE,
Plaintiff requests this Honorable Court to
equitably divide all marital property and debts of the parties,
COUNT III: ALIMONY PENDENTE LITE. ALIMONY
13. Paragraphs 1 through 12 are incorporated by reference hereto
as fully as though the same were set forth at length.
14. Plaintiff lacks sufficient property to provide for her
reasonable means and is unable to support herself through
appropriate employment.
15. Plaintiff requires reasonable support to adequately maintain
herself in accordance with the standard of living established
during the marriage.
WHEREFORE, Plaintiff requests this Honorable Court to enter an
award of alimony pendente lite until final hearing and hereafter
enter an award of alimony permanently thereafter.
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DIANE G, RADCLIFF
3448 TRlNDLE ROAD
CAMP HILL, PA 17011
(717) 737-0100
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COUNT IV: COUNSEL FEES
16. Paragraphs 1 through 15 are incorporated by reference hereto
as fully as though the same were set forth at length.
17. Plaintiff has employed Diane G. Radcliff, Esquire, as counsel
but is unable to pay the necessary and reasonable attorney's
fees for said counsel.
18. The Plaintiff is in need of hiring various experts to appraise
the parties' marital assets and does not have the funds to pay
the necessary and reasonable fees.
WHEREFORE, Plaintiff requests this Honorable Court to enter an
award of interim counsel fees, costs and expenses and to order such
additional sums hereafter as may be deemed necessary and
appropriate and at final hearing to further award such additional
counsel fees, costs and expenses as are deemed necessary and
appropriate.
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DIANE G, RADCLIFF
3448 TRlNDLE ROAD
CAMP HILL, PA 17011
(717) 737-0100
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VERIFICATION
DEBORAH L. ZEPP verifies that the statements made in this
Complaint are true and correct. DEBORAH L. ZEPP understands that
false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904,
relating to unsworn falsification to
authorities.
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DIANE G, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill, PA 17011
(717) 737-0100
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEBORAH L. ZEPP,
Plaintiff
v,
NO. 00-7692
JOHN C. ZEPP, III.,
Defendant
CIVIL ACTION - LAW
DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the Divorce
Complaint has been served upon the Defendant by Certified Mail,
Restricted Delivery on the 3rd day of November, 2000. The return
receipt for said mailing is attached hereto as Exhibit "AU and made
a part hereof.
CLIFF, ESQUIRE
Road
, P A 17011
Phone: (717) 737-0100
Fax: (717) 975-0695
Supreme Court ID # 32112
Attorney for Plaintiff
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DIANE G, RADCLIFF
3448 TRINDlE ROAD
CAMP Hill, PA 17011
(717) 737-0100
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Camp'lete item~ 1:' 2; cind 3:" Aiso complete
item -4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front if space permits.
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o Agent
o Addressee
Dyes
o No
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," rtified Mail 0 Express Mail
egistered 0 Return Receipt for Merchandise
Insured Mail 0 C.d.D.
4. Restricted Delivery? (Extra Fee) - "" Yes
2, ~Ujr5"l1~iP~lfZXDbelloc:v 6:1: ); lJ>LI T1~ j
PS Form 3811 , July 1999 Domestic Return Receipt
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102595-99-M-1789 .
EXHIBIT "AU
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DEBORAH L. ZEPP,
PlaintifflPetitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
JOHN C. ZEPP, III,
DefendantlRespondent
NO, 00-7692 CIVIL TERM
IN DIVORCE
DR# 30,186
Pacses# 229102800
ORDER OF COURT
AND NOW, this 2nd day of November, 2000, upon consideration of the attached Petition for
Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel
appear before RJ, Shaddav on December 7, 2000 a/9:00A.M. for a conference, at 13 N, Hanover St.,
Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony
Pendente Lite be entered,
YOU are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910,11t!;J
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required doctunents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E, Hoffer, President Judge
Mail copies on
11-2:00 to:
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, R, J, Shadday: Conference Officer I!
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YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. 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 MAY GET
LEGAL HELP.
<
Petitioner
Respondent
Diane Radcliff, Esquire
Date of Order: November 2, 2000
CUMBERLAND COUNTY BAR ASSOCIA nON
2 LIBERTY AVE,
CARLISLE, PENNSYLVANIA 17013
(717)249-3166
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YOUR HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. 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
MAY GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by
law to comply with the Americans with Disabilities Act of 1990. For
information about accessible ,facilities and reasonable
accommodations available to disabled individuals having business
before the court, please contact our office. All arrangements must
be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
BY OR FOR THE COURT:
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEBORAH L. ZEPP,
Plaintiff
v.
NO. (y) '1(.91- CU::J. T~
JOHN C, ZEPP, III.,
Defendant
CIVIL ACTION - LAW
DIVORCE
RE: PETITION FOR ALIMONY PENDENTE LITE
AND INTERIM COUNSEL FEES AND COSTS
TO
TH:':O:~L:~i:'HE~~y~:D 6UR& .
2000,
comes
the
Petitioner, Deborah L. Zepp, who files the this Petition for
Alimony Pendent Lite and Interim Counsel Fees and Costs and
respectfully represents that:
1. The Petitioner, Deborah L. Zepp, lS an adult individual
residing at 121 State Street, York Springs, PA 17372.
2. The Respondent, John C. Zepp, III, is an adult individual
residing at P) .0. Box 204, York Springs, PA 17372.
3. The Petitioner and Respondent were married on-June 8, 1974, at
York Springs and separated on April 10, 1999.
4, The Respondent has not sufficiently provided support for the
Petitioner.
5. The Petitioner is not on a financial par with the Respondent
in prosecuting and/or defending this Divorce action and is
unable to support herself in accordance with the standard of
living established during the marriage and to pay her
anticipated reasonable attorney's fees and costs incurred or
to be incurred in the within divorce action.
6. The within action is being instituted by the filing of a
Divorce Complaint concurrently herewith by the Plaintiff.
DIANE G, RADCl.IFF
3448 TRlNDLE ROAD
CAMP HILL. PA 17011
(717)737-0100
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7. That Complaint and this Petition represents the Petitioner's
claims for Alimony Pendente Lite, Interim Counsel Fees and
Costs.
8. A background information sheet pertaining to these claims has
or will be filed with The Domestic Relations Office as
required by Local Rules of Court.
9. The amount asked by the Petitioner for Alimony Pendente Lite
is the maximum amount provided for under the guidelines.
10. The amount of Interim Counsel Fees and Costs requested by the
Petitioner is $2,000.00.
WHEREFORE, Petitioner prays that the Court enter an Order:
1. Requiring the Respondent to pay the petitioner Alimony
Pendente Lite in the maximum amount provided for by law under
the state support guidelines;
2. Requiring the Respondent to provide medical support for the
Petitioner;
3. Requiring the Respondent to pay a reasonable amount towards
the Petitioner's Interim Counsel Fees and Costs.
Respectfully submitted,
DIANE G, RADCLIFF
3448 TRINDLE ROAD
CAMP HILL, PA 17011
(717) 737.QlOO
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DiANE G, RADCLIFF
3448 TRINDLE ROAD
CAMP HILL, PA 17011
(717) 737-0100
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VERIFICATION
I verify that the statements made in this Petition for Alimony
Pendent Lite and Interim Counsel Fees and Costs are true and
correct.
I understand that false statements herein are made
subject to the penalties of 18 Pa,C.S, Section 4904, relating to
unsworn falsification to authorities.
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DEBORAH L. ZEPP,
Plaintiff
vs.
JOHN C. ZEPP, III,
Defendant
ORDER
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 00-7692 CIVIL TERM
IN DIVORCE
AND NOW this Z ~; day of :J>u.-.VCr , ud" , upon the
Motion of the Defendant and the Stipulation of both parties, we hereby transfer this matter
to the Court of Common Pleas of Adams County, Pennsylvania, and order ,and decree as
follows to implement such transfer:
1. The Prothonotary of Cumberland County shall transfer and deliver, by
mail or otherwise, to the Prothonotary of Adams County all of the documents
filed in this matter and a certified copy of the docket entries of this case to
date, along with the original of this order,
2. The Prothonotary of Adams County shall assign a docket number to
this matter and treat it, thereafter, as if the action had been initia:ted in Adams
County.
3. Defendant will pay the Adams County Prothonotary's filing fee for the
opening of the action there.
Both parties are hereby directed to cooperate with the representatives of this court and the
Court of Common Pleas of Adams County to implement this order.
BY THE COURT,
/11
II
II
II
Distribution:
Diane G. Radcliff, Esquire
3448 Trindle Road, Camp Hill, Pa 17011
Samuel L. Andes, Esquire
525 North 12th Street, Lemoyne, Pa 17043
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DEBORAH L, ZEPP,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs,
CIVIL ACTION - LAW
NO. 00-7692 CIVIL TERM
JOHN C. ZEPP, III,
Defendant
IN DIVORCE
STIPULATION OF THE PARTIES
AND NOW come the above-parties and their attorneys, and stipulate and agree that
this action shall be transferred to the Court of Common Pleas of Adams County,
Pennsylvania, and that the court shall enter an order in substantially the form as the
proposed order attached hereto to implement such transfer.
, ESQUIRE
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SA L L. ANDES, ESC1UIRE
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DEBORAH L. ZEPP,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 00-7692 CIVIL TERM
JOHN C. ZEPP, III,
Defendant
IN DIVORCE
MOTION FOR TRANSFER OF CASE
AND NOW comes the above-named Defendant, John C. Zepp, by his attorney,
Samuel L. Andes, and moves the court to transfer this case to the Court of Common Pleas
of Adams County, based upon the following:
1. Both Plaintiff and Defendant reside in Adams County.
2. Neither of the parties reside in or have any real connection to Cumberland County.
3, Both parties have not consented to venue in Cumberland County. In fact, both
parties have agreed that this matter shall be transferred to the Court of Common Pleas of
Adams County, as evidenced by the Stipulation filed with this Motion.
WHEREFORE. Defendant moves this Court to enter the attached order to transfer this
matter to the Court of Common Pleas of Adams County.
~
Attorney for Defendant
Supreme Court 10 # 17225
525 North 12th Street
Lemoyne, PA 17043
(717) 761-5361
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COMMONWEALTH OF PENN5YL VANIA
COUNTY OF .ClJrll!!lERLAND Ct.'bAl\.lS
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JOHN C, ZEPP, III, being duly sworn according to law, deposes and says that the
facts set forth in the foregoing document are true and correct to the best of his knowledge,
information, and belief.
~~
G6 N C. ZEPP, III
Sworn to and subscribed
before me this ~.l,b. day
of \xQ~~ ,2000.
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! ~~ry Public
NOTARfAL SEAL
RICHARD E, SlARE, Notary Public
Latimore Township, Adams County
. miss'.on ExD;ros March 3, l!00I.l
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Court of Common Pleas Cumberland
County Pennsylvania
DEBORAH L. ZEPP
plaintiff
VS
JOHN C. ZEPP
Defendant
Docke t No. 00-7692 Civil
Civil Action Law
ADAMS COUNTY COURT OF CCMMON PLEAS
(V\Cl~e~
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PLEASE ACKNOWLEDGE RECEIPT OF THIS CASE BY SIGNING AND DATING THIS DOCUMENT.
.-
RECORD RECEIVED:
DATE:
<-
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(signature & title)
Please Mail back Attn: Becky - Prothonotary office
One Courthouse Square
Carlisle PA 17013
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OFFICE OF PROTHONOTARY
COURT HOUSE
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AUTHORITY TO PAY COURT APPOINTED COUNSEL
" COURT
o District Justice 0 Common Pleas
3. FOR ID,J.. C,P" APPELLATE)
o Appellate 0 Other
4. AT ICITY/STATE)
6, IN THE CASE OF
.;z ,Pf\/) vs ..;2..", CJ f)
9, PROCEEDI~GI!' IDescribe briefly) I ,
7. CHARGE/OFFENSE (PURDON CITATION)
11. PERSON REPRESENTED
1 0 "Defendant-AdUlt
2 0 Detendam-Juvenile
3 0 Appellant
4 0 Appellee
5 0 H.abells Peti!ioner
6 0 Material Witness
7 0 Parolee Charged With VIolation
8 0 Probationer Charged Wilh Viola lion
9 0 Other:
clJ/VtT) u /J14s,lo"--
, Q. PERSON REPRESENTED (Full Name)
Appl Dale
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16. NAME OF ATTORNEY/PAYEE AND
MAILING ADDRESS
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NAME OF COMMON PLE1IS JUDGE ASSIGNED TO CASE
Lindsay Dare Baird
37 South Hanover Street
Carlisle. PA 17013-3307
17, TELEPHONE No,
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CLAIM FOR SERVICES OR EXPENSES
1S.
SERVICE
DATES
HOURS
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a. Arraignment and/or Plea
b. Preliminary Heiuing
c. Motions and Requests
d. Bail Hearings
8. Sentence Hearings
t. Trial
g. Revocation Hearings
h. Juvenile Hearings
i. Appeals Court
~ Other ($peclfy on additlonalsheetS)j),u, Ma t:...H r
J\a'jl d). "~SJ-1I11b>1LI
~~ O~....:: TOTAL HOURS::s
s./. (J2-
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~PERHOUR
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20.
a Interviews and conferences
b. Obtaining and reviewing records
c. legal research and brief writing
d. Investigative and other work (Specify on additional sheets)
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TOTAL HOURS =
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AMT. PER ITEM
21. ITEMIZATION OF REIMBURSABLE EXPENSES
Mile80e $,25 oar mile x
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a, 0 PETTY OFFENSE
o FELONY 0 MISDEMEANOR
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12. CIVJI- DOCKET N;O~'0i
1"/.,tJ"Ims ('IM/iI/l
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13, CRIMINAL DOCKET NO
1 4, APPEALS DOCKET NO,
18. SO/~S;U57;O~E~~
AMOUNTS CLAIMED
Multiply rate per hour limes loral
hours to obtain "In Court8 com-
pensation. Enter total beiow.
1SA. TOTAL IN COURT COMPo
= $ S ;?.j---: to
Multiply rate per hour limes total
hours. Enter total "Out of Court"
compensation below.
20A. TOTAL OUT OF COURT
COMPo
=$ d'?-, S'6
21A. TOTAL ITEMIZED EXP.
=$
22, CERTIFICATION OF ATTORNEY/PAYEE f / 23, GRANO TOTAL CLAIMED
Has compensation and/or relmbu'~ent for work In this case previously been applied for? 0 YES /)if NO == $ ..<// ,.2.. _ r~
If yes, were you paid? 0 YES. /J.....NO If yes. by whom were you pald1 Howmuch~ 24. DEDUCT. PRIOR PVNTS.
Has the person repre~ented paid ~ny money to you. or to your kn~.~ edge anyone else, In co~n&Ctlon ~I~h the matter lor = $
which you were appOinted to provide representation? DYES.,)Q'" NO l 1f;t$S. g.l.~ detl)1lls _on additIOnal shee;.~ rlL-
I swear or affirm the truth or correctness ~ l1...t2urr::.. C/./ ~ ~ 25. NET AMOUNT CLAIMED
of the above statements S5gnalure of At10~yee Date = $ "/1 o? . -..iO
~B .oSI.: it/ )..4 I~ -Z- 27, ~M;- APZ./~' ~O
Copy 1 - Mail to ~ urt Adml~istrator at completi6n of service
26 APPRQVl ~ I '
. Hm SlQnature of
PAVMt;NI Judge
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