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Home My WebLink About00-08437 SAIDIS SHIJffi.!iOWER &~uSAY ATIIlRNlMI.nU&.W 26 W. High street Carlisle, PA " ~' ," --'-" PENNY D. SHERIFF, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000 - 1'4 ~ '7 VS. CIVIL TERM MICHAEL A. SHERIFF, Defendant : IN 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. (i " \i r [I 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 the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A 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, PENNSYLVANIA 17013 (717) 249-3166 SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: Date: ~/ t ( UfjJ C 01 . indsay, Esquire I 693 26 West High Street Carlisle, PA 17013 (717) 243-6222 Ii SAlDIS SHUflH!OWER &LlNIJSAY KlTORNlMl,MIL\W 26 W. ffigh Street Carlisle, PA ,_ - "c"" - , .' -~,;.-- PENNY D. SHERIFF, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2000 - ;'1-31 vs. CIVIL TERM MICHAEL A. SHERIFF, Defendant : IN DIVORCE COMPLAINT PENNY D. SHERIFF, Plaintiff, by her attorneys, SAlOIS, SHUFF, FLOWER & LINDSAY respectfully represents: 1. The Plaintiff is Penny D. Sheriff, who currently resides at 63 East Main Street, Newville, Cumberland County, Pennsylvania, where she has resided since 1991. 2. The Defendant is Michael A. Sheriff, who currently resides at 63 East Main Street, Newville, Cumberland County, Pennsylvania, where he has resided since 1991, 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 19, 1986, in Carlisle, Pennsylvania, 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she/he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. I, II SAIDIS SHUffi.!!pWER & Ul'IuSAY ATRlIINIMloAToIAW UW.H1ghStreet Carlisle, PA "__0, ,', ~" '," ",' - ,.. 0-", 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling, Date: Ii II WHEREFORE, Plaintiff requests the Court to enter a decree of divorce, SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: ~/. 2-uPO ( .2d" '~' -.",.; ";"'- ,\, ',' _0 _,':",~" ,-c' ,', ,",-.""" ';:,'<c;'J'<' ' l:,":. .- -" n' ,~'-~--;, " , 'CO,,"', ~..:.c ," VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S. S 4904, relating to unsworn falsification to authorities. Date: ! /- ~-()[) . . SAIDIS SHUffi.!!OWER &UNUSAY ATIOlINEYSoA1'IAW UW.B1ghStnet Carlisle, PA , ~",",,<,'; : ,.( -' ,,-','.-0-''' "~.~--ob' _, ('''/ ".'",' "_,"~'--',,~ . '~ _"~ '''-'''!.f""~- ,,";,,',. '-:J';:~ ~:.':~:O,; --,~:.-:, -- PENNY D. SHERIFF, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2000 - 8437 CIVIL TERM vs. MICHAEL A. SHERIFF, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, MICHAEL A. SHERIFF, Defendant above, accept service of the Complaint in Divorce filed December 5, 2000 in the above captioned matter. Mich A. Sheriff J;J. -z:,tl 63 East Main Street Carlisle, PA 17013 II <.:- "ill~n""'2;' -;, ~- "".'1 "~,,.1;<('~," ,.;~, '- '. ~,~,,~ 0' ~ ' , " ., -- '-~"i'-~"" ,'.' >:,,' _'~, ';i.,;: .- ( . .,'" '^ . "= ",-~"", . . .., ~';"V' .;;i,,_:,,;;,' _ ",,",," ,,_""U'" ~ - .'.. 0'" (") C C) C CO 'T~ ?' c:J ~ ~~.f: 1''''1 .~U) 65::~ ;-~,..) -<"': r=' ~C ~o 5>8 w z N ~~ ~ ~ to -,. -< ~ ~ . -=." ~. J,." !MI~; PENNY D. SHERIFF, Plaintiffi'petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE MICHAEL A. SHERIFF, DefendantlRespondent NO. 00-8437 CIVIL TERM IN DIVORCE DR# 30379 Pacses# 055103000 ORDER OF COURT AND NOW, this 23,d day of January, 2001, upon consideration of the attached Petition for Alimony Peridente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J, Shaddav on Januarv 31.2001 at 10:30 A.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. NOTE: The support conference previously scheduled before Sally Kreitzer will now be heard by RJ Shadday on the same date and time. 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 1910.111\:> (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 documents, the Court may issue a warrant fOT your arrest. BY THE COURT, George E, Hoffer, President Judge Mail copies on Petitioner 1-23-01 to: < Respondent C. Lindsay, Esq. Date of Order: January 23, 200 I l' ....'L-i V 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. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 , " _, ". _~_~ _'~'n OF I'j': r--r-, "~.._'.....,- ;..i:Lr~,krr\A: .Ct;r'''I"'.''','I' 'O"ARY '1''--.-'.''\.11;' I' 01 JI1fi24 Pi14: 15 CUMBE0:LANO COUN1Y PENNSYLVANIA lQ!f. " ~i1_,~~."",o~," J ~'$lli!{l~III~W"fiIJiI"!';j~ll'J'''!~~~~~ ,~ffi'-'f~~n"'jBfFi.''''''''~'' "'.~"t:'-:""'(~"'l,",'s<-~:~~~~-i!!fi?ftft~'fO!;;~~~~'!il/~~ SAlOIS, SHUFF & MASLAND A1TORNBYS-ATlLAW 26 W. High Street Carlisle, PA 'o..~''-''-. 0... ." ,,'- PENNY D. SHERIFF, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2000 - 8437 CIVIL TERM , , vs. MICHAEL A. SHERIFF, Defendant : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE NOW comes Penny D. Sheriff, by and through her counsel, SAIDIS, SHUFF, I FLOWER & LINDSAY and petitions this Honorable Court as follows: iii, ;11 'II I I 1. The parties hereto are husband and wife, having been joined in marriage on April 19, 1986 in Carlisle, Pennsylvania. 2. The parties separated on or about October 20,2000. 3, Petitioner is without the ability to earn income sufficient to meet her reasonable needs and to pay attomey's fees. WHEREFORE, Petitioner prays' this Honorable Court to order alimony pendente lite in an amount equal to the Pennsylvania State Support Guidelines and reasonable attorney's fees. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: rol J, Lindsay, Esquire I # 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 II SAIDIS, SHUFF & MASLAND ATIORNBVS-AT.LAW 26 W. High Street Carll.le, PA ',' ~,' , ., . _ .",'C '~', -'.'- -"--',,,' , '. -L,~ ,:,,: "0', .,,->-' '.... VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities, 4."~ Date: j- /8'- 0 I SAlOIS, SHUFF & MASLAND ATIORNBYS-AT.LAW 26 W, High Street Carll.le, PA PENNY D. SHERIFF, Plaintiff V5. MICHAEL A. SHERIFF, Defendant ,~ ",', " : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2000 - 8437 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE AND now, this / q 2001, I, Carol J. Lindsay, Esquire, of the law f SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys, hereby certify that I served the within Petition for Alimony Pendente Lite this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: , :! II Michael A. Sheriff 63 East Main Street Carlisle, PA 17013 SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: a I J. Lindsay, D 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 - "~ ,,"', " -i:liil>i" DR 36379 PACSES ID 655163000 PENNY D. SHERIFF, Plaintiff/Petitioner vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : DOMESTIC RELATIONS SECTION : CIVIL ACTION - LAW MICHAEL A. SHERIFF, Defendant/Respondent : NO. 00-8437 CIVIL TERM ORDER OF COURT AND NOW, this 220d day of February, 2001, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $1,960.75per month and Respondent's monthly net income/earning capacity is $4,200.39 per month, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $350.00 per month payable monthly as follows; $350.00 per month for alimony pendente lite and $0.00 on arrears. First payment due before march 9, 2001 and thereafter on or before the 10th day of each month. Arrears set at $700.00 as of February 22,2001. The effective date of the order is January 19, 2001. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.g 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the P A SCDU to: Penny D. Sheriff. Payments must be made by check or money order. All checks and money orders must be made payable to P A SCDU and mailed to: P A SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must iriclude the defendant's P ACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. -, '.--' - """,. i!i!!\.[' This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R J. Shadday ,M,"~, ~<t,:gQ, leso!).", " ';;t/, ;',.,' ,--~',~>j. '1"t(jt~f< . & BY THE COURT, Petitioner Respondent Carol Lindsay, Esquire Mark Schwartz, Esquire 1. , ~~-l&',i:!lliiri!~;lHmjiijWi"'~!i1l'J~~~~;;ili~tbJ,:tJ"""~;i'.i';'''H''~'''';'O''''!-'g~i!!l.I~~". = .,,- .~-- '" ~.. . " ., ~. "~ ,,' '. ~n:1.jtnnJ > "~,.al ~-<-~< ~"" "' p -.0;; [~~)/~~- <:_,:" t/;(' .~~~{~- fb ~:'7 -,.I , ~.-o ,-:-'; :~;~ ~: ::J t'0 (;0 ~>1''' _:~ -. .1';- ~ -"""""',..~~, ~ , ~L' ; ..'.1, '^ 'lA' ~-, '-"'. PENNY D. SHERIFF, PlaintiIDPetitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE MICHAEL A. SHERIFF, DefendantlRespondent NO. 00-8437 CIVIL TERM IN DIVORCE DR# 30379 PacseS# 055103000 DEMAND FOR HEARING DATE OF ORDER: February 22,2001 AMOUNT: $350.00 per month FOR: Alimony Pendente Lite REASON(S): DEFENDANT/RESPONDENT CONTESTS THAT PLAINTIFF MEETS THE REQ)JUIlMF.N!I:B FOR AN AWARD OF AT.TMONY PENDENTE LTTE. MARCH 9, 2001 Date SCHWARTZ, ESQ. , , '~$ih~"t;i'j;;b"""~'!!,",""~,~Rilb"'~-<lc',r""""'r-RI~;",,,,,,.E;ti;MlWjiSn;',(5.-'if';'''\l,,!;;.'(,~':,~;oWh'',i: '"'~''~.;i'fi,\1H~i'~<.k!):If~'''~~~-~~&!<''''''' '~1;:;: , - ^" ~-~- ..~ .' ^ -~=,~,~~ ^'~' -" ~< ,~.J ~ 1:[ '.J!! .' q I, Ii ,j !l ~I !I ,I J 'I I I 'I 0 0 ~ -U~ :x --e m~ ~ ;,:_,1 Zr'L ;;0 ~- "':::;':; zs: I :~1t8 CP~ \.0 -<Z: ~~~ ~~ ~O -0 ~O 3;; -_. ,.., QO )'>0 ~ Zm 2 0 =<! w ~ -< " IT ~ ". ',: "1..,;',,,,: ..., . ^""d;:~__: . ',..~'> ".,... . DR 30379 PACSES In 055103000 PENNY D. SHERIFF, Plaintiff/Petitioner vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNlY, PENNSYLVANIA : DOMESTIC RELATIONS SECTION : CIVIL ACTION - LAW MICHAEL A. SHERIFF, Defendant/Respondent : NO. 00-8437 CIVIL TERM ORDER OF COURT AND NOW, this 2Slb day of April, 2001, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $N/A per month and Respondent's monthly net income/earning capacity is $N/ A per month, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $276.00 per month payable monthly as follows; $276.00 per month for alimony pendente lite and $0.00 on arrears. First payment due on or before May IS, 2001 and thereafter on or before the ISlb day of each month. Arrears set at $607.34 as of April 25, 2001. The effective date of the order is January 19,2001. This order is based upon an agreement of the parties through their counsel and in consideration that Ms. Sheriff will make the car payment for the vehicle which she is driving upon receipt of regularly paid child support and APL. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.~ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the P A SCDU to: Penny D. Sheriff. Payments must be made by check or money order. All checks and money orders must be made payable to P A SCDU and mailed to: PASCDU P.O. Box 69110 Harrisburg, PA 17106-91l0 Payments must include the defendant's P ACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. '-,'l .. H,;;,;.'."""r~<~",,, ,,';;;';._j . Unreimbursed medical expenses that exceed $250.00 annually are to be paid 68% by the respondent and 32% by petitioner. The petitioner is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Petitioner is continue to provide medical insurance coverage through her employer. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for ahearingde novo before the Court. DRO: R. 1. Shadday ~JR~~on," '"1" ,.;. ~-r to: <- ta1 BY THE COURT, Petitioner Respondent Carol Lindsay, Esquire Mark Schwartz, Esquire J. ~~:liillH,"W~ii~~lJlli,~&;)~~~~~i1cll~~!i1!;;i&~""'ii"dW;',;,",,'-,,-,,'-n-filllil.'ilnnll U"' '~:IiIiIl - ", '",- .'~ .'-' "',' ." ~ ,.', ">~,~,~~~ ~ I . ~~ ,"" ,'- -' ,'"",.", ~ >,,,"' ~,,"', ~~~~., ,",,", ~,', - - .~ ~ ,," ~_OOI=_ liMliIil ~ """"'- (") 0 0 C -'1 s: ::ii: '"00:; cpr!' ~ "'-..C' -< ze- I .,",-31~J (f) ,,' -<"""" 0<::::. l~~ ~) !;.:C! ~o '" ")'" " ::J!: ~l~~ pO r:- r".;,'m c: '-.~,) Z b > =< 0'\ :n -< -,~ ~- f ~ L. . ,;" .,~ ",'~ _ ,1"" ~ 0 L)., In the Court of Common Pleas of CUMBERLAND County, Peunsylvania DOMESTIC RELATIONS SECTION PENNY D. SHERIFF ) Docket Number 00-8437 CIVIL Plaintiff ) VS. ) P ACSES Case Number 055103000 /D30379 MICliAEL A. SHERIFF ) Defendant ) Other State ill Number ORDER AND NOW, to wit, on this 22ND DAY OF OCTOBER, 2001 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or GgSuspended or o Terminated without prejudice or 0 Terminated and Vacated, effective JULY 1, 2001 , due to: PLAINTIFF'S REQUEST TO SUSPEND THE ALIMONY PENDENTE LITE. BY THE COURT: DRQ: RJ Slla<lday xc: petitioner respondent Carol Lindsay, Esquire Mark Schwartz, Esquire JUDGE Service Type M Form OE-504 Worker ill 21005 ~~~!'-~.-Ji'idjhl!l<J:ttq%'R!Wi!NW;l--"Il~'-'I!iIBl@1!!!'-jHJ"", 't'_"~':""~''''Y~''f5''''fi,,,,,,,,;i!h~~MTI!lIliI ,,", "lit"'" ~~~~:",,~_UIt- -.' , , ~ " , ,.. ~;; I I: I 0 C C) C - i ~ ~ c::> ._..1 -aCC 'C, m" "-l Z:L' Z r..,) ~Z::~: \.c r:r '. ~~.~, ..,-:.-.;-;.,,: >2:: ex) "- CJ Z ,~"1 ':.rl :"" -j :1:.1 -0, 'D -< . 4~"~ ~~ _', ~ SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT.LAW 26 W. High Street Carlisle, P A "" ;' 'r' l, '" _,.;",,,_, ...", "'.__; PENNY D. SHERIFF, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2000 - 8437 CIVIL TERM VS. MICHAEL A. SHERIFF, Defendant : IN DIVORCE PRAECIPE FOR WITHDRAWAL To the Prothonotary: Please withdraw the Complaint in Divorce filed in the captioned case, Penn I ' ' ~~llililll~,;r~,jIl1tug,;ftt1)!w;~' y ~ ~"'1'i!IIm~&'U"~;""';;e;jirki,.,,,;i;:0Mj,-jj,!lmi;~lll IT ~<in' '("iii ,=, ~!I{'- ~ " ~~'i.,.l ]1 ',,,,,,.~" ",~,'" ,l ":-'''''''','''''''~~~ ^C~ ,"''''''''''",""" ,"~ ,,0,'._ ,,_ "'-',"",',',"~,""',~__",~,~ -_',,,~e ,~,' _"_-"C' k"", ~ _>, L_ ~" , ., ", '~~" ,~'< '.. ..~ 8 ...., C> ~ <=> rit~ .... 0 5! ~~; ".., C") miifl -<5; (.,) ~~ '-c' ::!':: .' ~-ri ):i: ~ 40 :s:Q 20 ~ ~ (5m -I /'o,j 5:5 Q:> -< ~