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Home My WebLink About01-1975 FX ~~~ p . . . . . . .. ;t: ;t: ""'~ ,., :t::t::t: :+: :+: :+::+: :+::+::+::+: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . STATE OF . . TIMOTHY J. DeANGELO . . Plaintiff . VERSUS DANA M. DeANGELO . . Defendant . . . PENNA. No. 01-1975 CIVIL DECREE IN DIVORCE ;t- 1 ~ 4-~A "2#J ( , IT IS ORDERED AND . AND NOW, . DECREED THAT AND TIMOTHY J. DeANGELO PLAINTIFF, DANA M. DeANGELO , DEFENDANT, . ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . NONE . . ", ., 1: r-"I" 'I ~~ R HONOTARY . . ... . . . ,.,,., ,.,'" :4'~:4' '1"" '! J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :f ,.,"':.: '"---'" ~>~ i i I I Jl I i I !J l~ ii ,~' 'II :!I II 'i Ii,] "1 'I i ,< i I I I I , , ~ --, -.~' ',""..-~~>'"-'- ." ~ ~'~~' ,- ,_. ," "-"~ ~--. 0"' - . a ~ 'lJ '(Y') lyffl. Q-(- ~y; t.V --';0,) fCCY )"o~(J Jw 9t J-"'V~t.V !~to/:) . f'Y30 - IOfdlf'l::' ., '-~ , . "':"""'" :-V-~- ^ I '. ".,,~~~~~_":" __ '~~__",~ _' ,P!!', ,"- , 'c--' , ;'~'1:"~" JOHN H. BROUJOS HUBERT X. GILROY BROUJOS & GILROY, P.c. ATTORNEYS AT LAW 717-243-4574 4 NORTH HANOVER STREET 717-766-1690 CARLISLE, PENNSYLVANIA 17013 FAX: 243-8227 E-MAIL: brgilroypc@aol.com December 6,2001 E. Robert Elicker, II, Esquire Divorce Master 9 N. Hanover Street Carlisle, PA 17013 Re: Timothy J. DeAngelo vs. Dana M. DeAngelo; No. 01-1975 Civil, In Divorce Dear Mr. Elicker: Plaintiff withdraws the Motion for Master filed in the above case. Please file a Motion to Vacate the Appointment of Master. Enclosed are two copies of the signed Marital Settlement ment. Ijs c: Thomas J. Williams, Esquire >., ^ ,_, ~"o," _~~_ , T~ I~ I I I ~ , , >' OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, II Divorce Master Traci Jo Colyer Office Manager/Reporter West Shore 697-0371 Ex!. 6535 November 9, 2001 John H. Broujos, Esquire BROUJOS & GILROY 4 North Hanover Street Carlisle, P A 17013 Thomas J. Williams, Esquire MARTS ON, DEARDORFF, WILLIAMS, & OTTO 10 East High Street Carlisle, P A 17013 RE: Timothy J. DeAngelo vs. Dana M. DeAngelo No. 01 - 1975 Civil In Divorce Dear Mr. Broujos and Mr. Williams: Both counsel have certified that discovery is complete. Therefore, I am going to proceed with a directive for filing of pretrial statements with the understanding that we will not get involved in any discovery issues as we move the case forward. A divorce complaint was filed on April 4, 2001, raising grounds for divorce of irretrievable breakdown of the marriage. I assume that the parties will either sign and file affidavits of consent and waivers of notice of intention to request entry of divorce decree or have beel). separated for a period in excess of two years so there is no issue with respect to grounds for divorce. No economic claims were raised in the complaint. On April I 0, 2001, an answer and counterclaim were filed on behalf of the Defendant raising a claim for alimony pendente lite and counsel fees and expenses. Since the only issue pending before me involves a counsel fees and expense claim, I would permit counsel to deviate from the standard pretrial statement requirements as set forth in rule 1920.33(b). Counsel can submit income and expense statements, a list of counsel fees and expenses incurred by the Defendant who raised the . . 0 '," ,~- ,". "\'R",r,,"'J~_~' ,"",.;;-~ '7(', cp__, :~__"'_"_' '''>~'_,~-I~_'or:..''~-:''Y'~~"",~__ '=M'_'f" "', ',~'1''': "',:",_ -r_." ~ - I "" ~ - '_';-"_'" '"_'h. <_ _., ., Mr. Broujos and Mr. Williams, Attorneys at Law 9 November 2001 Page 2 claim, and any information that would be helpful to me in determining why, in this particular case, a claim for counsel fees is justified using generally the standards that the Plaintiff, against whom the claim is being made, has engaged in vexatious, obdurate, and obstructive conduct. The motion for appointment of Master indicates that a claim for equitable distribution has been raised and is to be heard by me; however, no pleading by way of counterclaim, amended complaint, or petition has been filed raising equitable distribution so we are going to consider only the claim raised which is for counsel fees and expenses. The pretrial statement as modified should be filed on or before Monday, November 26,2001. Very truly yours, E. Robert Elicker, II Divorce Master NOTE: Sanctions for failure to file the pretrial statements are set forth in subdivision (c) and (d) of Rule 1920.33. THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COpy SENT DIRECTLY TO OPPOSING COUNSEL. FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE MASTER MAY RESULT IN THE MASTER'S APPOINTMENT BEING VACATED. ~'.^" . '- "; .--. - , -~ 'P"11.'_:P- 1'--:' "'i.~'U_\""h. ;~~.:t'-:I7:'-'1"';~I"'~~~""'~F,W:",.It'~J!I;J1-'l'},,~!>~~.~r,ilt",:;'",~",_rl;;A"__.;U?f-", ~"."'""" ;'.-":>:<'~,;ri>',['~ ",'\ ^,y~,I'i!' ";.,,.. ~"- ,:,,,~,.;<< ".,'~ '~77",\,,,,'_a~.,.. ;,"','~' ,;..'_ry~"':-'""';- """"-~,R_"'~'-''';',:r,'L.'''''~''''''I!''l-_'''l''i..,".e_,",-,,:~....,,~_,, ,'~:'_'-"'I'!"', "'=," v: "",. , · MMA...R,.,T"".,.,', Qn..E,A...,.lRDVO..R..fF1..&.j, "'.IAMS,', (,f.. 5.'" ' . ~,u,w',:~".-';,> ,; ,:-_\ INFORMATION,.AovICE.Aoyo'CACY ,,--, " Nov,ember 8,2001 , ATTORNEYS:: '~' CO-UN~ELL.oRS_ AT- LAw , . W1LLiAM F. MARTSON . J,,"HNB. FOWLER III EDWARD L. ~~HciRPP D~I'.iIEL.-K;, D~RD.ORFF ,THOMAs J.~WIi..LIAMS" "...lvoy.OUoIll O-EO:RC;E B. FAL.LER ]R.* , ,.". <:;ARL .c.,RrSCH ;MARK'A. D,ENUr.1GER DAVID;'-R: ',G.AtEoWAY "'BOARD CERTIfiED CIVI.L T.RIAL $PEqAUST tEN liAST HIGH STREJ;:T CARLISLE, PENNSYl..YANIA 17013 TELE~HONE (717) 243-3341 FACSIMILE (7"17)243'1850 INTERNET ww'N.mdWo.com E.Robert Elicker, II,E$quire Office, of Divorce Master 9 North HarioverStfeet Carlisle,PA 17013 , ' . , . RE:, Timothy 1. DeAngelo v.Da)1itlI.DeAn.gelb No. 01-1975 -CilntberlandC6untyGC.P. Ow File No. 10312.1 Dear Mr; Elicker: -' '- :'" . '. ",,' - . , ~ " " ' , . , >" -" ," . Enclosed isaCenificati()nfor thelJefendant, D,arra M,DeAllgelo, tlratdiscoveryhas been completed. "., " Very truly yours, , , ' , . . MARTS ON DEARDORFF WILLIAMS & OTTO' , 'fk-'\fv.JL~ , Thomas J. '@.liaril$ . . . . TJW/tde Enc)oswe .. '. ." cc: John KBroujos, Esquire (w/enc.) F:\fILES\DATAFILE\Genlr:rocur\1031:2cre_l 1NFo.RMAT.IO:N 0 A.D,\fiCE oADY,OCA,Cy'M , . , 'J'""'rp''''""~''''''~,,,"''J'J'''''''~IT'''~~''~~'1''''~~'''"1'''''f_"'''''''''I_ >,,_ ~.,.....:...! -- '''t'''';'''''''I"' ,~~ -~. .;,";~".;. ~"lffll"""",_"",, _."_~~,"",,,~. ,~~"~""__~,,......,..._-=,~~--,-_, ~, ~. ,;,~:,,--,_, ,'" ~ ,. "-?illl"'ll'?6;,:;->J>:'" r,':, "'1-"',\""~""f""'~:,,,,!';;~',-':~.J;-~,~~,,,.:~;,, .", ;''').~'''--:-''~'''; "'':'''_''"''''';'~'~''_'~-''''':c; )'.-"""','l:-'\', ":~.:' >,~_- 't.'''-~ "r-' ,>Jj-"'t,, ~--,,~,:.,.,,! >'_-'~~'~','- r'>>"';;,'''-'' " :,,'J"-.\-!'_ ':'I_""C"_'-,~''''~''ir,'''-'-''- ~""':'"":';;:i-:""'->;:~"-'^"'~.c",~, "I",' ~,:~",-_>~",,,,,,,-,,,:-,.-,, M"DW&:6 INFORMATION-ADVICE.ADVOCACY ',-' . ,f\,rroRN'Eys,&'COU,NSELLOR5,AT'I..A.W: ' WIi.L~ F.:WRTS~,~ ]OflNIl;"FOWLERHI . EriwAAo L. SCHORPP .. 'DANIEi:l<~ tiEAR[)ORFF , THOM4srWlLLlMis' . l"dV OTTO III 'GEORG"B.FALLER]R,' ,,' " .' ," c;ARiC. I}1S<::H MARK A,"DENLiNGER' TEN EAsT HIGH STREET CARLISLE, PENNSYLVANIA 17013 TElEPHONE (717)243-3341 FACsiMILE (717)243-18)0 INTERNET- www.indwo.com. , , "-,.', ,_d" ,_ _' ,_', *BpARD CERTifiED -CIVW TIiIA.L ~PECIAUST . , ,November.27,2001 E.RobertEUck~r, II,:Esqu~re Office of Divorce Mastel' 9 North Han.ov~ Street Carlisle, PA 17013 '. RE: TimothyJ. DeAn~elov, DanaM.DeAn;gelo No. 01.19.7$ c CwnberlandCqUllty C.C.I~. Our FileNo. 10312.1 " Dear Mr. Elicker: Verytruly yours,' ,. . , MARTSONDEARDQRFF WILLLM1.S & OTTO 0"6-',.,,'..'. . .4k/d"..' '.,'..~ l ,.' #I>y/ . thoI1la.sJ.Williams ' TlW/tde ec: John H.Broujos, Esquire ,F:\FILEs\DATAFiLE\~l1ltr_cUr\I0312_rd ,',J ",:, , . ,- INFORMATION -,ADYICE -ADVOCACY"" , -,'- -",....,'S;,',~"r_"t....""''''~~~~'~~11 r'-~"'=i'~'-'IIM~"''''''''~'';~ r>' ,~"~,,,."',,., '",",""'.....~"""_''''...,,;.,.,., _>~"''''\ ~"""""'.'~.m , . - , , ,.-,~,.".;,;,..;,~-~._..;--_..:...::...:._---- .. .. , f TIMOTHY J. DeANGELO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant . : NO. 01-)97') CIVIL TERM : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your child. When the grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 '~:,~om.,!,~lIIII . I'l . ,-~ ,. , . ... - TIMOTHY J. DeANGELO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs CIVIL DIVISION - LAW DANA M. DeANGELO Defendant NO. 01- /975" CIVIL TERM IN DIVORCE COMPLAINT AND NOW, comes the Plaintiff, by his attorney John H. Broujos ofBroujos & Gilroy, P.c., and sets forth the following: I. Plaintiff is Timothy J. DeAngelo, who currently resides at 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Dana M. DeAngelo, who currently resides 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The parties were married on June IS, 1996 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties in this or any other jurisdiction. 6. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request 1hat the court require the parties to participate in counseling. 7. In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. -T:j- Jr-I ,r !'~ " - .' - '- WHEREFORE the Plaintiff requests your Honorable Co divorced from the Defendant. Plaintiff be 6268 April 4, 2001 F] 11 - - -' ~, ' ~ l'l. I "'"" - ~~ , . ~ - I verifY that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. Date: Apro '/ 'f, 2-00/ /ij~~ ~A'i!_'1 ~:"'''''''''''''_ ,__ ,~ 'r ~'O~"""', ,,_, ~ ~ "' <J ") --r! E ~ ~~ __, ~ ~"O \; ~. i; ~ ~ ~ '+> ~ . ~ . ~ "' ......,. ........... .., '. _...... ....... """.... .....1I'm .;' ...... c' c:: :::oc "Tii"'i-' .......... 11'7r--;."' ~ -N 3r- I:l ':') ;:::i). o ... r'-( d~"'" C:.:J~ ~ ;;;:' ~ :;~ -~ lV;:,-< Ol ~ s,~ c.:) :1.-::..... ~'J ~::1 I . ~.. ~ C"J 'I ~ v.$ .'. ~~~_~1I!m'l.1~! c.""""" M%l!! ~_"_.flIIl!W~1IiIW;~1\l,!,:_~,~~"'~{lf"':"">_'''"-',ni'sq;w<_" '''~~'V~''''''''I''_!,,''''''''"'''-'~')W!'.'''''~O!J'W'~'W''~~'''"~.f~m~~!l'1i!rf1jlR~ ~ .. d {. o ~ "'< --~J ':"J ::..") OJ -< ,'" .... TIMOTHY J. DeANGELO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. 01-1975 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I, John H. Broujos, Esquire, being dg,ly sworn according to law, do depose and state that a copy of the Complaint and Notice to Plei}iled in the above referenced matter was served on Defendant Dana M. DeAngelo by U.S. First Class, Certified Mail, on April 6, 2001 at the address below. Copy of Return Receipt is attached. Dana M. DeAngelo 414 S. Pitt Street Carlisle, P A 17013 December 17, 2001 John . Broujos, ire No. 6268 ey for Plain Iff BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 (717) 243-4574 (717) 243-8227 FAX Sworn and subscribed before me this 17th day of December, 200l. ~.,~ G,-WcvvJ , tary Public i Notarial Seal Bridget Ann Corcoran, Notary Public Carlisle Bora, Cumberland County My Commission Expires June 10, 2002 ,,,,-",,,"~j-~--'--'I "" TI , r' ~ ~~~ .~ .",-,<,-"",--",",-"., #.~.....!t"q~~;'fo;-,~%,,-'~:''''J~,,;';}'"'''''. + ~ sg:~ D. Is delivery address different fro item 1? ..;.. . ,!,!,:-~.~nter delivery address below: ~i\ ~ o Agent ~ 0 Addressee DYes o No SENDER: COMPLETE THIS SkTlON . I " . Complete-items 1,2, and 3. Also 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. J . Attach this card to the back of the mai1piece, or on the front if space permits. 1. Article Addressed to: o Express Mail o Return Receipt for Merchandise o C.O.D. DYes , 2. Article Number,Eo;>r.from service lab, .,/) ,0'7.1 5Y{jV oiJIPi'!(7)L(fr, 37J'C PS Form 3811, July 1999 / -"Domestic ReturnZ'C~iPt ")>,C/O.-ee. C~/--.:t-" ~. 'f-'(-O( 102595-99-M-1789 ">;C'r "'"''"'"'.... _, ..., '.~~.?~-" ~ ~ TIMOTHY J. DeANGELO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. 01-1975 CIVIL TERM : IN DIVORCE PLAINTIFF'S COMBINED AFFIDAVIT OF CONSENT, AND WAIVER UNDER PaRCP 1920.73 OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 4, 2001. 2. Defendant acknowledged receipt and accepted service of the Complaint on or about April 6, 2001. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a [mal decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 6. I understand tha1 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: 11;0 C> I ~~) - ,11~-,wlil! ,;1 ',- ." """"" ~ . ,~. ~'"^" ., I""'~~ ",,,,,II!I ~,_,~., w ,--, "~ ",'.' <'0=, ,~- -A"-~'~"";;'Tft"jjir1~,-^tif~JlwW:'o:'-i1--~"jtJ',i,'1t'H"t'hF'tf~l~ C) C! <'" ;:}2t;:: ;~1_1 L- , ~}:~~ r;2t -c-- C., ~~~~- Z -i -< c' C) , c::J ;'. C) , <y, -c:; ~) <::r. - . :D -< ~ ~~iI'i~~~~l!1~Ift\>I%i':'N!1-"'f'f,,~!n_'li~>;,w*m'_1-"",;" "~Y"~"'<:"-:,,:~,n"f,tH"-!l->""""""'P__'-JT,tr,~m<~'1F'!~j'F,;,n","<1","",,,y,'<H";'__"'~I'l-'~~<7J_~i! -~ . TIMOTHY J. DeANGELO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. 01-1975 CIVIL TERM : IN DIVORCE DEFENDANT'S COMBINED AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE, AND WAIVER UNDER PaRCP 1920.73 OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 4, 2001. 2. Defendant acknowledges receipt and accepted service of the Complaint on or about April 6, 2001. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date ofthe filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property , lawyer's fees or expenses if! do not claim them before a divorce is granted. 6. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy ofthe Decree will be sent to me immediately after i1 is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verilY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. !l4904 relating to unsworn falsification to authorities. Date: lz./:~I () J q}~ (jJ(~ Dana M. DeAngelo '_J'l.^:~~..,., 'I' ~" .. .", 1 . ~1"'1, " .~ r '" " " ",^"-"~~ ~ "" '-~"', "'-"W-""'-~'--l :"illIlt",c",d' ,.-~' c"",'}' _'Jq.l"T"~h-rr~~'1lii1-"i;''f.~Tl''t'Yl "ft'.;;"':1'ft"~~~~.:k14 (") -oi: rnr',' ZT' :2'" 0~~- r;~c ::;; -. ?.....\.,.." =() :;>c: ~ ~. c::) o ,-n ,~ , . \ cr, -0 :1r. i:.? 0-" ttr "...,..,.." ", "J"WIf;lJjll,~,."~~'lWlJ!1'~~0">'ffl)'ll!l_m:>:~~~~'I'l~m-~Il*_""_""'f;lWf"'V'"":"-O'<" '"-"":,"f."'{lt0;"'''1,~"1''f'P-"Y''fJ''''''''''.l'$,'lr'-"',~~wm'iI'!'''','''omm'f~""'W)~~O'+i!i{i",l10~~'Il.-\Wf:fji''R~~j1'T ~ " TIMOTHY J. DeANGELO : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW VB. No.01-1975 CIVIL 19 DANA M. DeANGELO IN DIVORCE Defendant STATUS SHEET DATE: ACTIVITIES: ~ ;~ - '-,~_""I- ~-, ~ , ,-c. r';I-~" - . I 1 ". " -- - \ ,,"C,..., . , "CO, TIMOTHY J. DeANGELO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01 - 1975 CIVIL DANA M. DeANGELO, Defendant IN DIVORCE TO: John H. Broujos Attorney for Plaintiff Thomas J. Williams Attorney for Defendant DATE: Thursday, October 25, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. 1'-1"'" ~I-'~- . 1-- . . ~ I . ,- ~. -. ~, ^ , \ ,~.,. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF COUNSEL FOR DEFENDANT NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. ,,_~ , _"o,~"P_'_,' __, ~---~ , . ~ - 1'1,' .f,;.- . '-1 ,,-, 1- ,-' ~ , F;\FILES\DATAFILE\Gendoc.cur\10312-pra ]/tde Created: 04109/01 10:51:55 AM Revised:, 04/09/01 10:'54:22 AM TIMOTHY J. DeANGELO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-1975 CIVIL ACTION - LAW DANA M. DeANGELO, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant in the above matter. MARTS ON DEARDORFF WILLIAMS & OTTO B\h1a?:.;;:tIs, ~q!!: *- Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Dana M. DeAngelo Dated: April9, 2001 " ."" n 1,1"'1 -. CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certifY that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: John H. Broujos, Esquire BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, P A 17013 MARTS ON DEARDORFF WILLIAMS & OTTO cgy j1~A.,IJ. Wf"'--() ricia D. Eckenroad ~ Ten East HIgh Street Carlisle, PA 17013 (717) 243-3341 Dated: April9, 2001 1'-', . < 1,1 I ,'r 1 - III ~. ~"..",..., "^"~""'''<''''''''__,~,_''''''"'~~'_~' ~~,'> ]J~._,.~""~..J..;," 17~ "~ .',0,'" "'_,_~ . '~'''.'"", ~ ." "''''''''lliIlI~'l~-mrT"''-'Y"\\'I{' o ~.;; ~~~\~;--: -,., zC~~ ~~-: ?;C' ~:::.c' ;./ ~.~;. C_" "':-.... ;J ~-:-\:) c:) ~""C) *', -~ ...--;'" :c, -< -- f~? .:;;"J (...) ~" , :::2 -,< _~'~''',,' ,.., '-"C"_ F' _~:" ~~~WT'_}1W:4JlFii"'_l,'*~~Jm~q!t "J""r._,_",,~,:i~ll~~., ~J:l. ~,.,T; F:\FILES\DATAFlLB\G<mdcc.cur\J0312-ans.1 Created 04/09J01I0:50:00AM ,Revised; 04109101 03:17:41 PM TIMOTHY J. DeANGELO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-1975 CNIL ACTION - LAW DANA M. DeANGELO, Defendant IN DNORCE ANSWER AND COUNTER-CLAIM OF DEFENDANT 1-7. Admitted. CLAIM FOR ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE 8. ~efendant requests your Honorable Court to allow her alimony pendente lite, reasonable counsel fees and expenses pursuant to Section 3702 of the Pennsylvania Divorce Code. WHEREFORE, Defendant requests the Court to enter a Decree ordering payment of alimony pendente lite, counsel fees and expenses as the Court deems just and reasonable. MARTSON DEARDORFF WILLIAMS & OTTO By 'lL~\N..tt~_ Thomas J. Williams, Esquire Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Defendant Dana DeAngelo Date: April 9, 2001 ";,,,,.,..~ ',~~o I-I" -I " , VERIFICATION The foregoing Answer and Counter Claim to Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. @n(11J1 g} r2A1/ ~/ Dana DeAngelo -'~""','~--~ t", 1'1 - I. CERTIFICATE OF SERVICE I, Tricia D. Eckemoad, an au1horized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Answer and Counter Claim of Defendant was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: John H. Broujos, Esquire BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO ricia D. Eckemoad en East High Street Carlisle, P A 17013 (717) 243-3341 Dated: April 9, 2001 -/I. . . I~II - 'j - !~I A (f!. -/ i'Ml pr> . 0 ::::~ ~ '" " ..l "\'> f _, x ", ~.. ~ ~~ ".' ~.. :"""-, " ."'''.'"..'..'B/llif~~1I''1I4"j'lltl1'"'lf'..'l\ii~lt.'i'''1 C) ;:F~ ~;:i:c (,- ,- -1.. J ~~-::; c.J ,~ -- ~ :::'1 -<: C? o "n ~ j? .. "- ~ " <. ~ r- ,..,. ~ r " ~,~~,j.:;l\i"l,--'J):;~D8'W'Jj~~iIIl'~..-i<~1;r':<-~',,,.,_"':"_~ ,r_'r-._~-':-I~~~Jir""",,~~!'w .-j ,-, i-:::! ,;-n \-':;:1 :'.1. C) -~; :::-{ --,~(") (~5rn :.;~_\ 5:) -< -0 \'-" "-.) '0 ... .. <:' 1... TIMOTHY J. DeANGELO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. 01-1975 CIVIL TERM : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Timothy J. DeAngelo, Plaintiff, moves the Court to appoint a Master with respect to the following claims: (X) ( ) ( ) ( ) Divorce Annulment Alimony Alimony Pendente Lite (X) ( ) ( ) ( ) Distribution of Property Support Counsel Fees Costs and Expenses and in support of the motion states: (I) Discovery is complete as to the claim( s) for which the appointment of a Master is requested. (2) The Defendant has appeared in the action by her attorney, Thomas J. Williams, Esquire. (3) The statutory ground for divorce is section 3301(c) of the Divorce Code - irretrievably broken. Plaintiff files this Motion under Section 3301(d) of the Divorce Code. (4) The action is contested with respect to the following claims: alimony, alimony pendente lite, support, distribution of property, counsel fees, costs, and expen (5) The action involves complex issues ofIaw or ct (6) The hearing is expected to take two days. Date: October I'f , 200 I ORDER APPOINTING MASTER AND NOW ~~~2001, ['J]~-t...ur~ with respect to the following claims: alL- Esquire, is appointed Mas1er By the Court: J. cc: John H. Broujos, Esquire Thomas J. Williams, Esquire ;,-,- " ')"_',1 .,...,.,,~ f'-- -! I. ~-" ~~-, !!ill . . ~~-...,..,..-~." ... '. VINVAlASNN3d A1NnO:J CN\F!,::!j8V~n8 lJS:OIWJ (ZlJiJIQ ^l:.1\ilCi\~C!"';-,L'~;:':: ~J ::!(i 3JI.:UO-c.:Cfii ,. . "-"i/"~':".'nJ'-~~lilli~;'iid'if:f-'hln_':flf:'f~'i.~~<'.rf1ti')t'"i'~"~-4;~-w~:ff:~,*1~ii\~;~:"~I,-;t' o !;;; ~'io- -oeD mm Z;tJ Z:C CfJZ ~/: c::c' >c: 2:(< J>c ~ o o """'1'1 ....; :T-,,_ rt'~p ---e'rn -:.nQ ~~ ~~~ :C~ (;2('~ grrt 5.< -<. c:::> ~ - '" -0 :::l: U1 o ~j\!~I~'JI~_~~~'4'l'!\l!'r{mi'i!~~ilIl!li"'1~*~I~""i(A"""'(I'I'-":<f"" t'N"_"'f",,-'"'_f':'"' "-""-:'~;'''{'''''''-~f'i'f'''~'''_JO>''''';",-;;j'0!f'if!;_['fJS!1j'~i!Ili~~~l'_ M~ OCT 2 9 2001~ , TIMOTHY J. DeANGELO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01 - 1975 CIVIL DANA M. DeANGELO, Defendant IN DIVORCE TO: John H. Broujos Attorney for plaintiff Thomas J. Williams Attorney for Defendant DATE: Thursday, October 25, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not compl~te in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. ';.,..., ",0" . I'r ;' I"" ,.,. I".'> '~" ." l' ,'r ~ n '"~, 1-'- ,^>_,t~,_", ,-W--.'! ~ ' (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. 10 zc, 0 I DATE V) ) FOR FOR NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. .- '~I:V~- '!"I""I"" -"I , -, TIMOTHY J. DeANGELO, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01 - 1975 CIVIL DANA M. DeANGELO, Defendant IN DIVORCE TO: John H. Broujos Attorney for plaintiff Thomas J. Williams Attorney for Defendant DATE: Thursday, October 25, 2001 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. 4~7l! ... II (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. /l/~ JOt DATE 'I' ~ {} .l/vJtd...__ COUNSEL FOR'PLAINTIFF ( ) COUNSEL FOR DEFENDANT (K) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. 'H~nR'!'~ r:'l" ,- j ,-,., ""1 .- T"~ -. ~'. '" ' . "~ TIMOTHY J. DeANGELO, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01 - 1975 CIVIL DANA M. DeANGELO, Defendant IN DIVORCE ORDER OF COURT AND NOW, this jfV'- day of ~.iJJJ 2001, the economic claims raised in the proceedings having been resolved in accordance with a marital settlement agreement dated November 27, 2001, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, ~ P.J. cc: John H. Broujos Attorney for Plaintiff ~~ ~JDDIItKs Thomas J. Williams Attorney for Defendant .,-, ~- ~I, I ., ,. " " ,. - !ll ) '."" ,., ,eo ,." ~-; =J ........1;IIlN!,,~:, , 0',' . e ". .. ,0 '" "'''''''':lfft"''u''Yi 1 r'nr'nrr"r~'lIlTnlrr "llfnt,\'IYt~ '1INViY1ASNr-J=Jd i..." 1'1,--r' c"- c, r~1 .-,t"'-'.')n" ,I'I!')') 'd\":;' !,nl_.;,,,,;;,r I j ._",-...'." \, . "H""" fl..... L(;:2~;!d l.-u~J]Ul!J J c' ~_.~~~i!,!P"""""'~";iW'If~[>"i..-t~~'l!l!fjtWJ_~l$JlJIIiI_~'~_jl~jjJf{m,,,,,,,~""_,_.".,.,4t...,~~-1 TIMOTHY J. DeANGELO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs : CIVIL DIVISION - LAW DANA M. DeANGELO Defendant : NO. 01-1975 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: April 6, 2001 by Certified Return Receipt Mail 3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: November 30,2001; Defendant: December 3,2001. 4. Related claims pending: none 5. Date Plaintiff's Waiver of Notice in !l3301(c) Divorce was filed with the Prothonotary: December 6,2001. Date Defendant's Waiver of Notice in !l3301(c) Divorce was filed with the Prothonotary: December 6,2001. 000 . Broujos, Esquire 62 Attorn y for Plaintiff JOS & GILROY, PC 4 North Hanover Street Carlisle, P A 17013 717-243-4574 Date: December 14, 2001 ;-!Y'W ,-~ -, ."~ - ~ . "~ .~ %":lEi'!Il;~:'iL!1;;j0'- " MARITAL SETTLEMENT AGREEMENT THIS IS AN AGREEMENT made this ~ day of November, 2001, by and between Timothy J. DeAngelo, of 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania. 17013, hereinafter referred to as Husband, and Dana M. DeAngelo, of 414 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Wife; WHEREAS, Husband and Wife were married on June 15, 1996, in Carlisle, Cumberland County, Pennsylvania; WHEREAS, the parties have one son, Hunter T., born August 28, 1996; and WHEREAS, various differences have arisen between Husband and Wife, whereby they have been living separate and apart since March 200 I ; and WHEREAS, the parties have agreed to maintain separate and permanent domiciles and to live apart from each other; NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound by the provisions hereof, the parties agree as follows: I, A. Wife conveys to Husband all of her right, title, and interest in real property jointly owned by the parties, consisting of residence at 414 S. Pitt Street, Carlisle, Pennsylvania, consisting of two-story semi-detached frame dwelling house, described in Deed Book 158 page 143, Husband agreeing to assume and to pay balance due under mortgage to James J. MacDonald and Veryl H. MacDonald, of307 S. Orange Street, Carlisle, Pa, 17013, and all judgments, liens, notes, and other encumbrances relating to said property existing and recorded on the date of this agreement and to indemnify, save, and hold harmless Wife against any and all claims, causes of action, suits or litigation for money owed, damages, indirect or consequential, including legal fees, arising out of failure of Husband to so pay such liens and encumbrances. B. Wife will execute deed upon signing of this agreement, to be held in escrow by attorney for Wife until final decree of divorce is signed by the Court, at which time the attorney shall deliver the deed to attorney for Husband; Wife in the meantime agreeing not to cause any judgments, liens, notes, and other encumbrances to be entered or imposed upon said property and not to impose any impediment to the divorce and to sign a consent and any other document required to finalize the divorce, C. Husband shall pay to Wife the sum of $6,500.00, which sum to be held in escrow by attomey for Husband until final decree of divorce is signed by the Court, at which time the attomey shall deliver the sum to attorney for Wife. ~"'"f\ ~"."""~_"'" _-<''!''1'"'"'' ~-" [ -,,- t'l,'_!", ~~ .., r .~" - ~rw::?,:':ei.~,tx,'-:'O~'2t 2. A. Parties have agreed between themselves on distribution of personal property owned, each conveying to the other all of his or her right, title, and interest therein. B. Wife conveys all of her right, title, and interest in 98 Chevrolet Malibu in Husband and Wife names to Husband, who agrees to assume and to pay and to indemnify and hold harmless Wife from any and all claims for the balances due to any lending institution for the vehicle, Wife agreeing to execute any documents required for the transfer of interest. C. Husband conveys all of his right, title, and interest in Toyota Corolla 2001 in Wife's name to Wife, who agrees to assume and to pay and to indemnify and hold harmless Husband from any and all claims for the balances due to any lending institution for the vehicle. 3. Blank. 4. Each party conveys his or her right, title, and interest in savings and checking accounts, life insurance, and pension programs in the name ofthe other spouse. 5. CUSTODY. The parties shall have shared legal and physical custody of the child Hunter in accordance with stipulation of the parties and court order to No, 01-1953 Civil Division, Court of Common Pleas, 6. ALIMONY PENDENTE UTE AND ALIMONY. Neither party will pay support or alimony to the other party. 7. Blank. 8. Except as otherwise set forth herein, each party hereby releases the other from any and all claims, or demands arising out of the parties right to equitable distribution of personal and real property under Section 401 of the Divorce Code, or any rights or claims in the personal or real property in the possession of the other party arising under the law. 9. Each party hereby releases the other from any and all claims, or demands for alimony or support, which claims or demands maybe based on Section 501 ofthe Divorce Code or under any other provision of the law. 10. Each party further releases the other from any and all claims or demands for counsel fees and expenses, which claims or demands may be based on Section 502 of the Divorce Code or under any other provision of the law. 11. Neither party shall contract or incur any debt or liability for which the party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations mcurred by the other party. !'.C~.,. - -~ - -~ I' I I n I .~ I .,. " -I 'r -~~ =~<~.~,~,- @;%1t..'tt<::~?I~~ ,."......'?tf: 12. Each party hereby waives, releases and relinquishes any and all rights that he or she may now have or may hereinafter acquire as the party's spouse under the present or future laws of any jurisdiction: A. To elect and to take under any Will or Codicils of the other party now or hereafter. B. 0 To share in other party's estate in case of intestacy. c. To act as executor or administrator of the other party's estate. 13. Wife hereby agrees to execute all necessary documents, pleadings or affidavits in order that Husband may proceed with obtaining a no-fault divorce. 14. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. If any provisions of this Agreement are held to be invalid or unenforceable, all other provisions shall continue to be in full force and effect. 15. The parties warrant and represent that they have made a full disclosure of all assets prior to the execution of this Agreement. 16. This Agreement shall bind the parties hereto, their respective heirs, executors, and assigns. 17. Each party has had the opportunity to have legal counsel to represent each of them in the negotiation and preparation of this Agreement and has either been so represented or has voluntarily chosen not to be represented. Each party has carefully read this Agreement and is completely aware, not only or its contents, but also of its legal effect. IN WITNESS WHEREOF, the parties hereto intending to be legally bound hereby have hereunto set their hands and seals the day and year first above written. ~ow~ ?,;:~./ Timothy. e 0 Qb~ 9la~" Dana M. DeAngelo -~~,!'gij~JlI.. , -1"1-"1 )1 "r' ~~ -'"~'" "~="