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Home My WebLink About01-03287 CHRISTOPHER A. SHRA WDER, Plaintiff * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, * PENNSYLVANIA * VS. * NO. 2001-3287 * DESMA M. SHRA WDER, Defendant * CIVIL ACTION - LAW * IN DIVORCE ORDER OF COURT AND NOW, this day of , 2002, upon consideration of the attached Petition to Modify Custody it is hereby directed that the parties and their respective counsel appear before , Esquire, the Conciliator, at Pennsylvania, on the day of , 2002, at o'clock, _.m., for a Pre-Hearing 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 a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By Custody Conciliator 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. OFFICE OF THE COURT ADMINISTRATOR 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 :1 -~,r..' . .,'_;~""<~.__\>~"t",,<, ,r . 'T'."., _"0",'.' CHRISTOPHER A. SHRA WDER, Plaintiff * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, * PENNSYL VANIA * VS. * NO. 2001-3287 * DESMA M. SHRA WDER, Defendant * CIVIL ACTION - LAW * IN DIVORCE ORDER ORDER OF COURT AND NOW, this day of , 2002, upon consideration of the attached complaint it is hereby directed that the parties and their respective counsel appear before , Esquire, the Conciliator, at Pennsylvania, on the day of , 2002, at o'clock, _.m., for a Pre-Hearing 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 a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: By Custody Conciliator 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. OFFICE OF THE COURT ADMINISTRATOR 1 COURTHOUSE SQUARE, 4TH FLOOR CARLISLE, PA 17013 (717) 240-6200 .",; -, " ",>; ~'_.' e.,.,,~ ,__ , "'-. ,>-,." , - -, '~'d"-"'''''''.'''''_'?~'''c',,,_ ;"-,,. u, ~ ,~, ., ~ CHRISTOPHER A. SHRA WDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001- 3.;2S') CIVIL TERM DESMA M. SHRA WDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including cus10dy 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 Prothono1ary'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 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 "l,i-'i1"ftf_.." v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO.2001-3.2n CIVIL TERM CHRISTOPHER A. SHRA WDER, Plaintiff DESMA M. SHRA WDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Christopher A. Shrawder, through his attorney, Thomas S. Diehl, makes 1he following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Christopher A. Shrawder, is an adult individual who currently resides at 207 Birch Lane, Carlisle, Cumberland Coun1y, Pennsylvania 17013. 2. The Defendant, Desma M. Shrawder, is an adult individual who currently resides at 207 Birch Lane, Carlisle, Cumberland Coun1y, Pennsylvania 17013. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were rnarried on September 21, 1996 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between 1he parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. f~, _ , , . <,~ . , ~ """", 7. The Plaintiff has been advised of the availability of counseling and the right to reques1 that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire tha1 the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' rnarriage is irretrievably broken. WHEREFORE, the Plaintiff, Christopher A. Shrawder, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. S 3301(c) or 3301(d) of the Divorce Code. ubmitted, 5 -~~-(9( Date: Afb omas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX '>'ifoj', ~ ~ " '1- ~r ~."",,," VERIFICATION I verifY that the statements made in this Complaint are true and correct. I understand that false staternents herein are rnade subject to the penalties of 18 Pa.C.S. 9 4904, relating to unsworn falsification to authori1ies. ~A~ CHRlSTOPHER A. SHRA WDER, Plaintiff I~ '-'_', ;-,~_;-:__ ":~T",~,,~?,,::')~,,':1"', '~"""~_""-c~' - , "" ",'_0 '," 1': ,", ",<- -~,". ~, , CHRISTOPHER A. SHRA WDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001.3287 CIVIL TERM DESMA M. SHRA WDER, Defendant : CNIL ACTION - LAW : IN DNORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties of this action separated on Mwy It 1 100 / , and have continued to live separate and apar1 for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. S 4904 relating to unsworn falsification to authorities. Date: JiL..i;v j;tJ I r~ 14 ~ CHRIS OPHER A. SHRA WDER, Plaintiff fi"..."....., r''"" _.(." , , - .~ '" ',- . '">'llI!JJ,~W . >,"", , "" ~lH. () C) <:> c: W -r1 ;g: '- ___1 -ceo S; "~~;~ ('1'1r'p , zj:: I ::g@j Z'j:: ~2, -' Lib, _.---~ -~ ~c:; -" . .. '")-'-' ~Q ~ 'zo .- ,~,m $e, '-d :::{ r ~ ~ )0- 0:> ~ .~ r1:~~9ifi:~I~Rlft~~~~il~l~r.I~I[_~Ti~_~g,_m~'!lI'!,}-~,m"h''''Wf'';'~:1".'-::_"'-"'hn'}'~f'~:'~lWf~-WW"i!i~jnHk0%-W,~'\i"l!i,'l~>l~~~ .. CHRlSTOPHER A. SHRA WDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-3287 CIVIL TERM DESMA M. SHRA WDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A cornplaint in divorce under S3301(c) ofthe Divorce Code was filed on May 30, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from ilie date of filing and service ofthe Complaint. 3. I consent to ilie entry of a Final Decree of Divorce after service of notice of intention to request entry of the Decree. 1 verify iliat ilie statements made in this affidavit are true and correct. I understand iliat false s1atements herein are made subject 10 the penalties of 18 Pa.C.S. S 4909 relating to unsworn falsification to auiliorities. Date: q)~'v"J~~ =A~~intiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree in Divorce wiiliout notice. 2. I understand that I may lose rights concerning alirnony, division of property, lawyer's fees or expenses if! do not claim thern before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and a copy of 1he Decree will be sent to me immediately after it is filed wiili the Prothonotary. I verify that ilie statements rnade in this affidavit are true and correct. I understand that false s1atements herein are made subject to ilie penalties of 18 Pa.C.S. S 4909 relating to unsworn falsification to authorities. Date: q /li;./,);{! !4Y /f) ~ Christopher A. Shrawder, Plaintiff ;"'-';"~'_"lol~,IQ !I;ll"~'l!_ . ~ , . - ~"~ ~ ~ - ,~ ~r "1 i , !'!'~" PJ!': ,~ .. , _ IL_lilljnn"M~"~- ~,." 13B.l~WI: o ~ "'OeD ITJ,fT Z-," Z~' g!~:~ r~ ::::::-"-J ;'>"'--' Z".l ;>C) c:: z :;! o N U) ,.." ""0 (,,) <::> o 'T, ::F# ~~~ :3 -:;;.(!:; ~~=H :~~~:~ '..> ._, ~~< ,< "t') ::n:, ~ (,~. ~,.J ~~'P"f'@!~~;'F"':;?""''''':o''f''''K'''-FJ(;;''\~f#!'''i~'~~~Jimi~~U\IP~~~~~ ~ " CHRISTOPHER A. SHRA WDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-3287 CIVIL TERM DESMA M. SHRA WDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this ih day of June 2001, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Christopher A. Shrawder, and states that he had cause to be mailed a certified copy of a Cornplaint in Divorce to the Defendant, Desma M. Shrawder by certified, restricted delivery, re1urn-receipt requested. A copy of said receipt is attached hereto indicating service was made on June 4, 2001. Respectfully subrnitted, u<lW Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX ''-''''-" "' ~,~~, "'"^ ~" ."l<. """",. , . ci ~ RE'CMlI!t~~INT CJ Postage $ to.55 =r ['- U"l U"l Certified Fee . Return Receipt Fee Q""" (Endorsement Required) C C RestrIcied Delivery Fee CJ (Endorsement Required) CJ 1b1a1 p...... & Foes $ ~ 1lJ, ru Name (EI~f!!! PrInt CIe.M!n. (1!1 be compJe by fir) rn Dh"l:iMA M. SHRAWDER '" , Q""" Siftiei,.AjiCiio:ro;:jicrjOiN;;..._....,_._._._.,~:::::t~~~../..., g:; _._2_Q1._~.IRCH._LANE..._____.._._._._..__________ ...... CIIMShW.Z1P+4 ' , . - ['- _Compl"te items' 1'.2. and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse 50 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. 1. Article Addressed to: D. Is delivery address different from item 11 If YES, enter delivery address below: DESMA M. SHRAWDER 207 BIRCH LANE CARLISLE, PA 17013 o Agent I o Addressee I o Yes I o No i 3. Service Type D Certified Mail 0 Express ~ail o Registered 0 Return ReCeipt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) XD Yes 2. Article Number (Copy from service label) 7099 3220 0009 5574 0330 10259S-00-M-0952 PS Form 3811, July 1999 Domestic Return Receipt ,,~;- -"'",,-,,,,-, , """ ~" ' '7- ". -~ ., . ,~ -" ;: Ii ,1 " I ~ I: Ii " I' . ~ ~. .'~' - " ", '~,mu '.'-' '<'~' ~'.~'" ~.~~, '0,,", ... . (") C} ~ ~~ C -n 5:: <- ,- ""00) c:: -n mfTi :;:e: 2,::u .-,~tr.? 2:C CI>~,: CO (~{r: -<.<::'-- r-i'.-' .1:,_,' $::-.... "'" ~-H Zr~ ~ ~~ ~fi pO c ==:; ~ c:- ?iJ (::> -< _, ..,.,J '1 <".-..-,~,i.,~Jii$~-lm'~'!fW,~"'~~~;W!!f.~~'~:,~Pi!.~ij~l~;~JI'!,'~~~~~ ~!' 1>>." . CHRISTOPHER A. SHRA WDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001.3287 CIVIL TERM DESMA M. SHRA WDER, Defendaot : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 19th day of August 2003, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Christopher A. Shrawder, aod states that he had cause to be rnailed ao Affidavit Under Section 3301(d) of the Divorce Code with Counter-Affidavit to the Defendaot, Desma M. Shrawder by certified mail, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on August 2. 2003. Respectfully submitted, T s S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Carlisle, Pennsylvaoia 17013 (717) 240-0833 (717) 240-0893 - FAX 'Ii;;: '''', ,,",, ' ",'_',' _ _ _ ~,~ A ," ~ ,..' ..I" .. . . I"- o o o Certified Fee RelurnReciept.Fee {Endorsement Required) Cl Restricted Delivery Fee r=l {Endorsement Required) :;r ~ '1l\ a<9 "pJ $ ....2 '" I I f1J lolal po,>age & Fee, I, ?~q,)-l ru ' -~ Cl s'nt~To "" L#. ~~L.:-~.___m..m' ~ 7T /.-Xu: VTTp~r.c~ " ~ 'sfraet, peNO.; ~.m_".." "~..m. - -. . ~ . . :11 - II $1.75 $0.00 "--' ..':'-"',','-,,' ",-- ",,"" '""",' , , . 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. . Attach this card to the back of the mailpiecB, or on the front if space permits. 1. Article Addressed to: COMPLETE THIS SECTION ON DELIVERY A. Signature ~~ D. Is delivery address different from item 1? If YES, enter delivery address below: x B, ~# #'rY~#.N;z>c.< ,(&rd57/~L~4,.'€. c?ft';t..v~'u", yJ/1 /?tJ/3- 3. Service Type "Ijfsertified Mall 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Oe"'1ery? (Extra Fee) 0 Yes 2. Article Number rr fans'er from service labeQ PS Form 3811. August 2001 7002 2410 0007 8502 5117 Domestic Return Receipt 10259S.Q2--M-103S . .~- .~ ~~t " .. .. .. 0 C) 0 C c..,) "'n ~ en ~~; r'1 ::,j '''0 ;:;:; :lJ L::T , ZC ! e'f!'lJ:J ~:~:,: CO Tr ~~::-' :::~ --:~tJ -~-"J", J;'- .- :]; ;05 "11 -.' L>-..; '7() $-<'" cD ;'"jITI C. Z ::...., :11 )..">. =2 Il \0 -< .. ,~ "oC" ,~,1li]!,;J~~", -1,....'~"- ,~, ~h;~,~ t:JI'H;~~~,l',!'r'i':r;''i'lINi';!1,;ij{i'<.')~!B'I%J;&::,,,,.~~,,"~~~~~;!!~,"~~ )~j~fijl~I~.",~"~_~ . , '" CHRlSTOPHER A. SHRA WDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-3287 CIVIL TERM DESMA M. SHRA WDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 10th day of Septernber 2003, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Christopher A. Shrawder, and states that he had cause to be mailed the Notice of Intention to Request the Entry of g3301(d) Divorce Decree with accompanying Counter- Affidavit to the Defendant, Desma M. Shrawder by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on September 6,2003. Respectfully subrnitted, mas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX I''''''' , , , . r ,:,"~="\,_,.",- . --, " ,'~ ,~ < "" - , . .". I" .,""" ~, "" ,~,,/- " ',,' "'.':'''' 3-'- ru r'\ Ll1 ~' cQ.F..Ei1ltC I A L Ll1 ..:l _$ r-- Certtfiecl Fee CJ CJ Re1IJm_Foe CJ (Endoniemem Required) CJ R_CeIloI<HyFoe M (Endorsement Required) =r- ru Total Postage & Fees ru CJ CJ ('- , , . Complete~einii 1, i, and 3. sO 9Oni~lete item 4 ~ 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 pennits. 1. Article Addressed to: ",*",1< ~K# /I Y:~MP~ ,ul cP#t!# ~ {!//~afU, y1l /7(//3-. 2. Article Number (Transfer from service labet) PS Form 3811. August 2001 _," - .,r.''f.-,';,' ''', [J Agent [J Addressee C. Date of Delivery ,6-3 D. Is delivery address different from item 11 0 Yes If YES, enter delivery address below: 0 No 3. Service Type ~ertified Mail 0 Express Mail [J Registered [J Return Receipt for Me<chandlse o Insured Mail [J C.O.O. 4. RestMcled OeIlvery? (&fra Fee) 7002 2410 0007 8502 5124 Domestic Return Receipt 0_ ",~ SEP 0 8 2d~95-02-M-<l'''' . g- 1'1L.=~""~ .., " ~. sr? UJ~~ ()~/ U~::,-.' !i ' ~~ ,~ I n Lei fJ~~ LL o N u:: S r- z :;:-'< C)--, ,,7 u;" ,--, ::i :~~ -,~ /.- ,,,-,~,7 i,UtU :l-)[L -~ ::; (.) Z ~-C o LL l..<J v: r.--J c;::; ,- ",., ,"" ~..' ,P~''"'!' ~w o~.". -~"-~,- ~ ~iV '.-l~. '" ~< . ..i"<illii!l, ,,,~_,,^'" ~'''"''^''''~"!JI!III'''''"''.~~'T~~!lU'",'M'i'Jit'I~.t'IJ'\'.T,",:,v,,f1t~,,'l''';r;l!!ill-*i'~)jf!j!il'iiWf~~;~,~1fijl~1!tW~~~ CHRISTOPHER A. SHRA WDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-3287 CNIL ACTION LAW DESMA M. SHRA WDER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this I 'f~ day of rn 1/ 'f , 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Christopher A. Shrawder, and the Mother, Desma M. Shrawder, shall have shared legal custody of Tyler C. Shrawder, born June 15, 1996, and Ashton M. Shrawder, born October 18, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to rnake all rnajor non-ernergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The parties shall share having physical custody of the Children on an alternating weekly basis, with the exchange to take place each week on Sunday at 5:00 p.m. The non-custodial parent shall be entitled to have a period of custody on Tuesday (or other day as arranged by agreernent) frorn 3:30 p.m. through the following Wednesday rnorning when that parent shall take the Children to school or day care. 3. Each party shall ensure that the Children get to and from the school bus stop during his or her periods of custody. 4. ,Every year, the Father shall have custody of the Children from the Saturday before July 4 through the Sunday after July 4. The parties shall cooperate in scheduling periods of custody for the Mother to rnake up for any regular period missed during the Father's week of custody under this provision. 5. The parties shall share or alternate having custody of the Children on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 1 :00 p.m. through Christmas Day at 1 :00 p.m., and Segment B, which shall run from Christmas Day at 1 :00 p.rn. through December 26 at 1 :00 p.m. In even numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. In odd numbered years, the Mother shall f""'''''-'ii9L ,_ ~ ~, ~l ~, ,~~ - ,.,=< ,,,,,, ~ ~ w_ , .'. ,- '^'" ",- ~ . 'W_' '~", ,',' >c,-'~.. ''''~'''.,,_ '~~,' " _~ -.... ....._~.....'. VINVA1ASNN3d )JNnOO G'l'ilHj[jVvm f' I :~. ',.: 'd . I :! -"' 'i AVWZO AtlVIO;'JC: 3~)I.:i:X) i,~~1ji1ill'l I ~ 'l~("', 1~!lf!(~""""'IlU."_,,,,,,,_,", _ ,g,*it~~--'!;Yi~'W'>';;1"1i',"~~W;,~,,"';'[';':~~4H,,'5-~i~~j~~ir"'~~1i:1liii!f~~~~~ .. have custody of the Children during Segment A and the Father shall have custody during Segment B. B. NEW YEARS/EASTER/THANKSGIVING: The parties shall equally share having custody of the Childrer1 on New Years Day, Easter and Thanksgiving each year, with the specific exchange tirnes to be arranged by agreernent. C. MOTHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Children every year for Mother's Day and the Father shall have custody of the Children every year for Father's Day, with the specific tirnes to be arranged by agreement. D. The holiday custody schedule shall supersede and take preceder1ce over the regular custody schedule. 6. In the event either party is unavailable to provide care for the Children during his or her period of custody for 4 hours or more, that party shall first contact the other party to offer the opportunity to provide the care before contacting third party caregivers. 7. Neither party shall do or say anything which may estrange the Childrer1 from the other parer1t, injure the opinion of the Children as to the other parer1t, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children cornply with this provision. 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties rnay rnodify the provisions of this Order by mutual consent. In the absence of rnutual conser1t, the terms ofthis Order shall control. BY THE COURT, cc: Jennifer L Frechette, Esquire - Counsel for Mother Thornas S. Diehl, Esquire - Counsel for Father 4i J. ~ -5-j,!J'. o.:v CJ-. r~,IllQ.i.,"" . - " , ~^"' CHRISTOPHER A. SHRA WDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-3287 CIVIL ACTION LAW DESMA M. SHRA WDER, Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator subrnits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tyler C. Shrawder June 15, 1996 Ashton M. Shrawder October 18, 1999 MotherlFather MotherlFather 2. A Conciliation Conference was held on May 7, 2002, with the following individuals in attendance. The Father, Christopher A. Shrawder, with his counsel, Thomas S. Diehl, Esquire, and the Mother, Desma M. Shrawder, with her counsel, Jennifer L. Frechette, Esquire. 3. The parties agreed to entry of an Order in the form as attached. /11(j Y( JnOo [)~~ Dawn S. Sunday, Esquire ~ Custody Conciliator Date ff',~~_" ~t" ~''''' ." - " - -~"' .L",," CHRISTOPHER A. SHRA WDER, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY, PENNSYLVANIA * VS. * NO. 2001-3287 * DESMA M. SHRA WDER, * CIVIL ACTION - LAW Defendant * IN DIVORCE CERTIFICATE OF SERVICE I, Wendy L. Shive, Legal Assistant to Jennifer L. Frechette, Esquire, hereby certify that on March 13 2002, I served a true and correct copy of the Answer and Counter Claim upon Thomas Diehl, Esquire, counsel for Plaintiff, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Thomas Diehl, Esquire One West High Street Suite 208 Carlisle, P 17013 Date:,1/Fsj6L ~.~J?~~ Wend);: Sfnve ' I., ,',J, ;_c ,",_, ,,,'-,C'J ,";,-'i," ,u..._ - -. ," '-~ "c ,.", ,_,"'~"O". ,- ,',' ~ <- . PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHERA. SHRA WDER v. 01-3287 CIVIL ACTION LAW DESMA M. SHRA WDER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, March 20, 2002 , upon consideration of the attached Complaint, it is hereby directed that par1ies and their respective counsel appear before Dawn S. Snnday, Esq. , the conciliator, at 39WestMainStreet,Mechanicsbnrg,PA 17055 on Tnesday, April 16, 2002 at 8:30 AM 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday. Esq.tr^ Custody Conciliator (J The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone (717) 249-3166 "~'I .~', ~.", ,,' -.: - '" " ". .',M ~l;j~"i!~';j"'i'J~"l~!i"""~~--"i~':1'!:'l:':l;'j,\",,,"';j:;?'16it\litit",,_~,"~j-!iBH"j j'"",-,,:;";' 3 -dO t/d- J .;)tI - tJ) JdO .(},) "~^~ ~b_~~~Jii! "8j~"""~''''''''-''',:4;j.rl~~:; o;tw,;-!!i: . 'u~~:.f.t~=klJ MIII!IlIlll2"-,-^ ng:n:jIT,*lM1i1iJk. .--, .- " ^ _n, ~ / :"'['=J1ARY 02 r:rr; ? 0 -" '). cq ,J" ;},... , ., CUi'Vil.:!i::-':L,/,\ CGdNTY F E:'\jl\j3\1".J/lN~/-\ (jJ. ~ ~~ %;" aI'_pJ~ ~ 4d.b ~ q-- iJJ) ~'~I ~'af'~ . ^~ hO CHRISTOPHER A. SHRA WDER, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY, PENNSYLVANIA * VS. * NO. 2001-3287 * DESMA M. SHRA WDER, * CIVIL ACTION - LAW Defendant * 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. Ajudgment 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 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, Cumberland County Court House, 1 Court House Square, Carlisle, Pennsylvania, 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 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ,~,' . _-,-,~ 1,: '"'-'C,1<>",,' '::"'--;<",.'." 0 '""~ ""~' """ c ,-'-""_~ ,'f""",,!,,~ " ". ,', ,~" ,-,,),, .~,--"- , .,~ - CHRISTOPHER A. SHRA WDER, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY, PENNSYLVANIA * vs. * NO. 2001-3287 * DESMA M. SHRAWDER, * CIVIL ACTION - LAW Defendant * IN DIVORCE ANSWER AND COUNTER CLAIM COMES NOW, Defendaot, Desma M. Shrawder, by and through her attorneys, Weintraub & Associates, to lllake this Answer and Counter Claim, and in support thereof, avers as follows: ANSWER 1. Denied. Upon information and belief, Plaintiff currently resides at 209 Faith Circle, Carlisle, Cumberland County, Pennsylvania 17013. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted. "'"~ ,V,,^, ~~" _, '''P 0,.",,,,,,""..,,,. . ,~ COUNTER CLAIM COUNT I. REQUEST FOR CONTINUED MAINTENANCE AND BENEFICIARY DESIGNATIONS OF EXISTING POLICIES INSURING LIFE AND HEALTH OF BOTH PARTIES UNDER S3S02(d) OF THE DIVORCE CODE 10. The prior paragraphs of this Answer aod Counter Claim are incorporated herein by reference thereto. 11. During the course of the marriage, Plaintiff has maintained certain health, life and death insurance policies for the benefit of Plaintiff and Defendant. 12. Pursuaot to Section 3502( d), Defendant requests Plaintiffbe directed to continue maintenaoce of said policies. WHEREFORE, Defendaot respectfully requests that, pursuant to Section 3S02( d) of the Divorce Code, the Court enter an order directing Plaintiff to continue to maintain certain life aod health insurance policies for the benefit of Plaintiff aod Defendaot. COUNT II. REQUEST FOR APPROVAL OF ANY SETTLEMENT AGREEMENT AND INCORPORATION THEREOF IN DIVORCE DECREE UNDER SECTION 3104 OF THE DIVORCE CODE 13. The prior paragraphs of this Answer and Counter Claim are incorporated herein by reference thereto. 14. The public policy of the Commonwealth of Pennsylvania encourages parties to a n1arital dispute to negotiate a settlernent of their differences. '~~;< , ','~ -,,, ~, - <"~_~'-_"_',l'~';r,,,~_~,_,^_~" .-' ~ 15. While no settlement has been reached as of the date of the filing of this Answer and Counter Claim, Defendant is and has always been willing to negotiate a fair aod reasonable settlement of all rnatters with Plaintiff. 16. To the extent that a written settlement agreernent might be entered into between the parties prior to the time of hearing on this Answer aod Counter Claim, Defendant desires that such written agreement be approved by the Court and incorporated in any divorce decree which rnay be entered dissolving the marriage between the parties. WHEREFORE, if a written settlement agreement is reached between the Parties prior to the time of hearing on this Answer aod Counter Clairn, Defendant respectfully requests that, pursuant to Section 3104 of the Divorce code, the Court approve 'lnd incorporate such agreemer1t in the final divorce decree. COUNT III. REQUEST FOR CONFIRMATION OF CUSTODY UNDER g3104(A)(2) AND 3323(B) OF THE DNORCE CODE 17. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 18. The parties are the parents of the following unemancipated children who reside with Defendant: NAME AGE SEX DA TR OF BIRTH Tyler C. Shrawder 5 Male June 15, 1996 Ashton M. Shrawder 2 Male October 18, 1999 19. During the past five years, the children have resided with the parties and at the addresses herein indicated. 'F ." r~~' l' ',' ,_ "" ',c' _;_0"0,,, 'W~'_ __~~' ;'" FROM ill WITH WHOM ADDRESSES Birth May 2001 Mother and Father 207 Birch Lane, Carlisle, PA 17013 May 2001 Present Mother 207 Birch Lane, Carlisle, PA 17013 20. Defendant has not participated in any other litigation concerning the children in this or any other state. 21. There are no other proceedings pending involving custody of the children in this or any other state. 22. Defendant knows of no person not a party to these proceedings who has physical custody of the children or who claims to have custody, partial custody or visitation rights with respect to the children. 23. The best interests of the children will be served if custody of them is confirmed in Defendant. WHEREFORE, Defendant respectfully requests that, pursuant to SS 3104(a)(2) and 3323(b) ofthe Divorce Code, the Court enter an Order confirming custody of the children in Defendant. Respectfully submitted: WEINTRAUB & ASSOCIATES Date: ~ \B \60 BY: Je i r L. Frechette, Esquire 26 0 North Third Street Harrisburg, P A 17110 (717) 238-2200 In #87445 ATTORNEY FOR DEFENDANT ,'f, , . ~' '. e,r", ~ -" - -- <, , ,'",'"",~ -"" .,e, '_ ",' ,,"'__,~, _. " ,- ~ ,',~ ''" VERIFICATION I, Desma M. Shrawder, hereby swear and affirm that the facts contained in the foregoing Answer and Counter Claim are true and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: ~/Od- ~tuvma 'If- 9/rro.lld/? Desma M. Shrawde ,';t'", _' .-c,.'" ~".,.,." C""., ''7- ~_. ". .f_" O~ -':- ,"'."" ,~ , . ~ ~ ~ jt ..... '" '" ('. ..... (.., l;:1 ~ ~ "'" '" 0; I.l ~~. ~ 4,~JIR.~~, _ ,.-,~WM~j''''''''',<!'?{fl!~:U~ii?>~~~'~. '" '" '-\ & () c <:' ~~. en..:- -<:':0 ' r::c:,' ~K )>~~ :~ "- t ~ C) 1''',) () -','1 -.,,} r,,_, co -.-j ~ ('5 .;~.,. fll C_J -., "'r~, :I:J --< ;-.....:' "-~ . ,~,J , C:J c) g' ~ -- CHRISTOPHER A. SURA WDER, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY, PENNSYLVANIA * vs. * NO. 2001-3287 * DESMA M. SHRA WDER, * CIVIL ACTION - LAW Defendant * IN DIVORCE CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Jennifer L. Frechette, Esquire, hereby certify that on August 15,2002, I served a true and correct copy of the Petition to Modify Order of Custody and Order of Court scheduling a Custody Conciliation Conference upon Thomas Diehl, Esquire, counsel for Plaintiff, by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Thomas Diehl, Esquire One West High Street Suite 208 Carlisle, P 17013 Date:.nj If) 0 8 ~l-,O,~ Misty D. Lehmk ','7;",.,,,,,_",,_,,,,., ~., ^"'"~Ik;t"" ,,~<~,~,,_" ,",<, "'~ ." .-,,~ ,- > ,,,T '-I --,-,',,"," i, ~,~ ,_ ,,--" ~.~"" 'u. "","'"' ~, "_~"~ ~.,~, ~, Il[!'fl:,~~__ .'~ .,. 4.," ~,,_, ""'~>',"'_ - --"0_"""""""'",,,~,,,_ .;H "C. <,.~~~~ - (") (~ <.::" Q)F~! ~ _/ !;~ ~~~~ =2 o '1 :.:Jr;lI :~=) 'T"! ;-:::::' ,-,)'f"j JCJ ~.~;(:) ,'"1-' r~)::D ~.J i~~~ S --< 1.0 ::-:"'" _.;,~ .,~ ; h3 ~ ,~:~;~~i!:f;'\'Y,ii.:,,!m-"-<iii'W'\'"'&l-~~~,~I~~rn~fWft~,~~~ ,- ...~ " , .. - - ....tJVL vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V AN1A NO.01-3287 CIVILACTIONLAW CHRISTOPHER A. SHRA WDER, Plaintiff DESMA M. SHRA WDER, Defendant IN CUSTODY PRIOR JUDGE: Kevin A. Hess CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tyler C. Shrawder June 15, 1996 Ashton M. Shrawder October 18, 1999 MotherlFather MotherlFather 2. A Conciliation Conference was held on September 26, 2002, with the following individuals in attendance. The Father, Christopher A. Shrawder, with his counsel, Thomas S. Diehl, Esquire, and the Mother, Desma M. Shrawder, with her counsel, Jennifer L. Frechette, Esquire and Stephanie Mihalko, Esquire. 3. This Court previously entered an Order in this matter on May 14, 2002 under which the parties have shared physical and legal custody of the Children. The Mother filed this Petition to Modify, seeking primary physical custody. At the Conference, the parties were able to agree that neither party would make non-emergency telephone calls to the other party's home either after 8:00 p.m. or before 7:30 a.m. As to the remaining issues, the parties agreed to investigate the financial feasibility of engaging in co-parenting counseling and to recontact the Conciliator to advise whether a counseling provision should be included in an Order. As the Conciliator has been informed by the Mother's counsel that neither of the parties' insurance coverage applies to counseling, the parties have decided to forego the counseling alternative due to the financial situation. Consequently, the entry of an additional Order is not necessary at this time. () c.. fv~ Date III .2-c)(J ~ I ~a.-~ Dawn S. Sunday, Esquire Custody Conciliator cc: Thomas S. Diehl, Esquire - Counsel for Father Jennifer L. Frechette, Esquire - Counsel for Mother ~~ /0.30-0.h ~ "<P!""'.__llJ~~,.._ "n' . ~_-4rc ,~ o ^ " :1 Ii !; ii 1-, i:~ <'" ... =, ""' L "" 'r.""~' ~ -- .~~" " . --, -~, , ~ ~~ " '_"'~ ~,~ ,'_ ~'e w__ ~"_.,~, '. ... '.. " ,-:.\\ .-; '3\'-\\'" (~ "",,, "\'1\\,,;1)\ \F'~ .";'...'i::s-(~ \),', \...... 'ij ''''~ (\'\'-..,\1 ',i: ..,-.' rr{ '__.' I'\'-\I\V,> ' ,I.,J,; c' I' \ 1.11:.> ,_\.~ \,.0 S\J'v ...,(''\ "\'j n, );J' ,," ,- . .'- })j~ )s~;g;;~:,:\\r;\:\ ",",," ~ rl__-'~~~~__;"l,"'>l""_~~~~iJJI1 ~ ._~,t~~f-~""%'!"@''''-~''-''-1;;-"'''11~'';'' ~V~'; , CHRISTOPHER A. SHRAWDER, . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY,PENNSYLVANIA . VS. . NO. 2001-3287 . DESMA M. SHRAWDER, . CIVIL ACTION - LAW Defendant . IN DIVORCE RULE AND NOW, this L day of /tvrw- V" ,2003, a rule is hereby issued to show cause " why the within request should not be granted. RULE RETURNABLE~ .20 DAYS--!Lc;:. .J"<..fV,...... BY THE COURT: ,4J J. <<~ ~~",,? .6' O~.D\P .~-~-, ,- ,r ~ , ' , , , i , i I: I i 1 I I i I il !'- ~~~i!i(;,&"r<;Jilj~'~ " VlNVI\lASNN3d - ' -" ,r.. '~"'"In''' ! ,,"(:1('" , . .,-- iIL'-'n'l1l ,f n"l.:'-;i',-:,\' ',"" '_'",-_.1i. '-' S I :8 H~ 9 - J[W SO }.HV\ ()i'-;,-,;; ': ,,,',),J:j ,~ ~." ,,-)! 1.J('t--('\~:I'li-1 :J,-J:':~'V '-' ..., oJO ~l!l"im~~~I'~~IfiIIl!I!l~~~l!!:!~~'~\%.1Ii',#'rW"?'M"':'"';"i'.'-P\I"'''-',~'it0T'''_",".~,:';''';T-O:ij'';(H'''';ti"i~~"E''',~';eh'''"'';;!i~:.:ft:;:';,"J;r!'W3)-fijl'~'~''''!'!'lf*'' CHRISTOPHER A. SHRAWDER, . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY,PENNSYLVANIA . YS. . NO. 2001-3287 . DESMA M. SHRAWDER, . CIVIL ACTION - LAW Defendant . IN DIVORCE PETITION TO WITHDRAW APPEARANCE Jennifer L. Frechette, Esquire hereby respectfully petitions this Honorable Court for Leave to Withdraw her appearance as counsel for Plaintiff, Desma M. Shrawder, and in support thereof, avers as follows: 1. Petitioner is Jennifer L. Frechette, Esquire. 2. Respondent is Desma M. Shrawder. 3. Petitioner was retained by Respondent in 2002 to represent her in her various divorce, custody and support matters. 4. Petitioner has undertaken such representation but is unable to continue for the following reasons: a. Respondent has disregarded an agreement with Petitioner as to fees and costs and withdrawal is allowed pursuant to Rule 1.16(b)( 4) of the Rules of Professional Conduct. To date, Respondent owes Petitioner over $1,500 in fees and costs. 5. Petitioner has communicated to Respondent that she intends to withdraw as counsel for Respondent. A true and correct copy of said letter is attached hereto as Exhibit "A." " -. "~, .~ ". , ,,,.,. , .~ -,- "1 r ,"- WHEREFORE, Petitioner respectfully requests leave to withdraw her appearance as attorney for Respondent. Date:~{h i/1J p t7k1Jv Jenni er L. Frechette, EsqUIre Petitioner VERIFICATION I, Jennifer L. Frechette, Esquire, verify that the contents of the foregoing Petition to Withdraw Appearance are true and correct to the best of my knowledge, information and belief. I understand that I am subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities for any false statements that I made in the foregoing document. Date: LP\1~ (d) ~ J~ fer L. Frechette, Esquire "-':i!il"1]' ~ O~ , , ' .,~,~ 'q ~-, EXHIBIT "A" "- 1,- ,~ LAW OFFICES OF EDWARD J. WEINTRAUB & ASSOCIATES PRACTICE LIMITED TO F AMIL V LAW 2650 N. THIRD STREET HARRJSBURG,PENNSYLVANlA 17110 (717) 238.2200 FAX - (717) 238-9280 E-MA!L - EWDIVORCE@AOL.COM Edward J. Weintraub Jennifer L. Frechette* Stephanie L. Mihalko * also admitted VA Bar Legal Assistants Misty D. Lehman February 5, 2003 Desma M. Shrawder 207 Birch Lane Carlisle, P A 17013 Re: Outstanding balance Dear Desma, Your bill for legal fees and services remains outstanding. The outstanding balance at this time is $1,539.50. You must pay this bill in full within ten (10) days of the date of this letter, or call our office to make satisfactory payment arrangements if you cannot pay the full amount now. If payment is not received, or a satisfactory payment arrangement is not made, we will have no alternative but to immediately file with the Court a Petition to Withdraw as your attorneys and send your account for collection. You will not receive additional notices from this office regarding your account. This is your final notice. Please honor your obligation so that collection actions may be avoided and we may continue to represent you. Thank you for your cooperation. Yours truly, Daniel Stem COpy DS/mdl ,~j;:;; ,~, , - '-, :"'" CHRISTOPHER A. SHRA WDER, . IN THE COURT OF COMMON PLEAS Plaintiff' . CUMBERLANDCOUNTY,PENNSYL VANIA . VS. * NO. 2001-3287 . DESMA M. SHRA WDER, . CIVIL ACTION - LAW Defendant . IN DIVORCE CERTIFICATE OF SERVICE I, Sherry A. Fitzkee, Legal Assistant to Jennifer L. Frechette, Esquire, hereby certify that on July 2,2003, I served a true and correct copy of the Petition to Withdraw Appearance upon the following individuals by depositing same, postage pre-paid, in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Thomas Diehl, Esquire One West High Street Suite 208 Carlisle, P 17013 Desma Shrawder 61 Gasoline Alley Carlisle, PA 17013 Date:~ ^."t',,_ ..-:,,1 ",f' ,.. " ~ '!['; ~ ,,~ 'lll-.! "lllI!Jl!I\~~~l!ijt~'i,-&~~,,::,j'~''''~'''''',,-"!j, '<..c-"'~,,;,'~' (") ~ ~ll~ ih_~, ~~:~- fit ? ~,,-, ~'? C'1 .f';:- -"~ 2~ !::) " :..:=t-. 'ii-!:!- ;........) ~ :? .r) r~;= r- !"\) (,"":; ..; o ~:~nl :';, -< q. k-f) ;',YK"''''~~i':,'i;''I>'l1jWifl!iHH;ljji'1/'Ii\'1f*0-'J''I'#~';Wl1f'~ilj[mf'~~ CHRISTOPHER A. SHRAWDER, . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY,PENNSYLVANIA . YS. . NO. 2001-3287 . DESMA M. SHIRAWDER, . CIVIL ACTION - LAW Defendant . IN DIVORCE CERTIFICATE OF SERVICE I, Sherie A. Minich, Legal Assistant to Jennifer L. Frechette, Esquire, hereby certify that on August 11,2003, I served a true and correct copy of a Rule and Petition to Withdraw Appearance with regard to the above-captioned matter upon the following individuals by depositing same, postage pre-paid, in the United States Mail, Dillsburg, Pennsylvania, general delivery, addressed as follows: Thomas Diehl, Esquire One West High Street Suite 208 Carlisle, P A 17013 Desma Shrawder 61 Gasoline Alley Carlisle, PA 17013 Date: ?/;; ko I I /)u~ jJ. f/)AJc:A - ,lSherie A. inich - 1-- _~_""""1 i'" -,-- . < - "~~~ =~, , ,Jl'~' '" 'I I :O_I~I, ~, ',uL" . _". ",-_ "~.. (') C ~:, ;:g ft~ ~~c ~~.. -< o c...:~ ~ c: en c, ::;fl c ',~ - '''T, c:- rT1 ,:7J~-; r-:) , ";'JC; -- "T -'1'" )0 ;..::,;rn ';::-:'[ -';".. ::0 ,< <n ",~~!I"~~~I!l!Yn!m:mIRUl~!i1I~Pff";>J;H:,"",""?"" '''-';;;Fe, ---'":,'-5,"'W""''i'if0"~'ltth''.j~;,,,;~c,,::~&;i:,,~j';i~iJ;oifI'l''''l"{IVffi:ff\'il''''f1Vl~'10~I~ CHRISTOPHER A. SHRA WDER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 01-3287 CIVIL ACTION LAW DESMA M. SHRA WDER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 14, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39WestMainStreet,Mechanicsburg,PA 17055 on Wednesday,September04,2002 at 11:00 AM 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday. Esq. Custody Conciliator \Y ;/' The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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, YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone (717) 249-3166 "'~k.,~ <-- 'I -,.",~~ , 1 ~ ~ilill;i'I'Mif";!!{i;)~ii!~ilt!iM'''MI,1I:ili,li'~li<w;N~~14<''@\\t~ii''$''":'''i.;",'~-' .'~~-",,,.,:.,, _-,j"'-__,"'-,-!(~1U-1i':&*,'j-~ "'~ti.iil:H'-'~' ~)iINr.-~ -'" OF' Q?_ ',[,1,,", ,I I",,' ~ 1 . _(_,H I... 1';";- i:' _< t! Cu",;,,:,,'-, " ',",,' I....:..;"h, f-',I'dJ' i " ,,' i,'I''")' - "~ '" .J;....~ 'I PENNSYLVANIA . </ 1f!-tIc) 'if/l/ 0,.) .?/~'t!) M' ~ ~ Z; a-#uJ~ 5t?~~ ~~.d~ ~~~a:J~ ,- ~"""'~"'= _" ,'_''''''',_''_'"'"''<"" ""'-'~'^,"'''''''_ '""_~=,,_ "'~.' ., ~_J ~.,_o, ~"~,= --" . CHRISTOPHER A. SHRA WDER, Plaintiff * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, · PENNSYLVANIA * vs. . NO. 2001-3287 . DESMA M. SHRAWDER, Defendant · CIVIL ACTION - LAW · IN CUSTODY PETITION TO MODIFY ORDER OF CUSTODY AND NOW, Defendant, by and through her attorney Jennifer l. Frechette, Esquire, files a Petition to Modify Order of Custody, and in support thereof, avers the following: 1. Plaintiff is Christopher A. Shrawder, Father, who currently resides at 209 Faith Circle, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Desma M. Shrawder, Mother, who currently resides at 61 Gasoline Alley, Carlisle, Cumberland County, Pennsylvania. 3. The parties hereto are the parents of the following minor children who currently reside at 61 Gasoline Alley, Carlisle, Cumberland County, Pennsylvania and 209 Faith Circle, Carlisle, Cumberland County, Pennsylvania. Tyler C. Shrawder Ashton M. Shrawder Age 6 Age 2 4. On May 14, 2002, the Court entered an Order of Custody, granting Plaintiff and Defendant shared legal and physical custody of the children. A true and correct copy of this Order is marked Exhibit "8," attached hereto, and made part thereof. 5. Plaintiff/Father's girlfriend has become abusive with Defendant/Mother and has attacked Mother's sister. 6. Plaintiff/Father has not been cooperative with Defendant/Mother's request to continue the children's schooling in Cumberland Valley where they currently reside. 7. Plaintiff/Father has not been cooperative with Defendant/Mother's requests to keep the children out of day care on her weeks of custody. 8. Plaintiff/Father has verbally attacked Mother in front of the children, cursing <-. ,""" ~,' -, ~ ~ _"",,~'1_, " ~ '''''_ at her, ripping open her car door and snatching a bag from Mother's car, causing the children to cry in fear of Father's temper and abusive behavior toward Mother. 9. The best interest and permanent welfare of the children will be served by a modification of the Court's Order, specifically: Granting primary physical custody of the children to the Defendant and granting partial physical custody of the children to the Plaintiff. WHEREFORE, Defendant respectfully requests that this Honorable Court modify its Order as follows: Granting primary physical custody of the children to the Defendant and granting partial physical custody of the children to the Plaintiff, Respectfully submitted: Date:~ Jen i e L. Frechette, Esquire ATT RNEY FOR DEFENDANT 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 1.0.#87445 y,+--.,~" '" 7 -',--, " -;,-"-', " -<~-~', '.' O'-"""",_o,~" -, < "-,c,_"" ;"' " VERIFICATION I, Desma M. Shrawder, hereby swear and affirm that the facts contained in the foregoing Petition to Modify Order of Custody are true and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: fJ /(p /0:) / I J)L/.Ym() _ '5J/;rawan Desma M. sma::!' ""', -,", """""-';";-'",2', ""'-~~';F.."'-' ~, ~"""_,_",,, "-'~~-'-"'''~r'''c'' , '" . . . ' EXHIBIT "A" -f..-_: ,:":,-,:"__,:-",!""",;,,.,:,",,o"'"":'_":'_l'""_- ~__'''',:",-_:. ,', :,-,-,'"F,~-.~c';-_'__""";,__,,,,_:_~ _, ,_ "_ _"_~" __ , CHRISTOPHER A. SHRA WDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01-3287 CIVIL ACTION LAW DESMA M. SHRA WDER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this N e:- day of ~ ' 2002, upon consideration of the attached Custody Conciliation Report, t is ordered and directed as follows: 1. The Father, Christopher A. Shrawder, and the Mother, Desma M. Shrawder, shall have shared legal custody of Tyler C. Shrawder, born June 15, 1996, and Ashton M. Shrawder, born October 18, 1999. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The parties shall share having physical custody of the Children on an alternating weekly basis, with the exchange to take place each week on Sunday at 5:00 p.m. The non-custodial parent shall be entitled to have a period of custody on Tuesday (or other day as arranged by agreement) from 3:30 p.m. through the following Wednesday morning when that parent shall take the Children to school or day care. 3. Each party shall ensure that the Children get to and from the school bus stop during his or her periods of custody. 4. Every year, the Father shall have custody of the Children from the Saturday before July 4 through the Sunday after July 4. The parties shall cooperate in scheduling periods of custody for the Mother to make up for any regular period missed during the Father's week of custody under this provision. 5. The parties shall share or alternate having custody of the Children on holidays as follows: 't A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 1:00 p.m. through Christmas Day at 1:00 p.m., and Segment B, which shall run from Christmas Day at 1:00 p.m. through December 26 at 1:00 p.m. In even numbered years, the Father shall have custody of the Children during Segment A and the Mother shall have custody during Segment B. In odd numbered years, the Mother shall ',".","""',, ' ", ,"" ~~ ~ have custody of the Children during Segment A and the Father shall have custody during Segment B. B. NEW YEARSIEASTERlTHANKSGIVING: The parties shall equally share having custody of the Children on New Years Day, Easter and Thanksgiving each year, with the specific exchange times to be arranged by agreement. C. MOTHER'S DAYIFATHER'S DAY: The Mother shall have custody of the Children every year for Mother's Day and the Father shall have custody of the Children every year for Father's Day, with the specific times to be arranged by agreement. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 6. In the event either party is unavailable to provide care for the Children during his or her period of custody for 4 hours or more, that party shall first contact the other party to offer the opportunity to provide the care before contacting third party caregivers. 7. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, /s/ 1~ (2. I~ I I J. cc: Jennifer L. Frechette, Esquire - Counsel for Mother Thomas S. Diehl, Esquire - Counsel for Father rl~'1\1) 'j;''''''' ''''''d'''''''''''''''''V I'''' 'J"" (:. ",r-,', "l;"",~ ,.. ~._," ..;f~ , in T~i'!n~n~-~y r""?~f t~..~ ,?'II"! "h~'" ~" ,~" "P~ ~,--;.~ '.r-',,~ "'~, ,1, ,"0" ,~' ."" ";, -...~ ' anti tl~t!' .::;'!~'k.t~ ~o"l'~ i~~,r...1 t"...,jtl~ ~ ih LU1 ~t~!~~;~ Y3. ThlL~dJY llL~__~, <2~ ~ rt.-~ ~ Prot!1mlctar.t :r~....~ "'<r"'" " c,,,',,=_,__,"~__ 'c" .', "_, -,,, .~ vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.01-3287 CIVIL ACTION LAW CHRISTOPHER A, SHRA WDER, Plaintiff DESMA M. SHRA WDER, Defendant IN CUSTODY #. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tyler C. Shrawder June 15, 1996 Ashton M. Shrawder October 18, 1999 MotherlFather MotherlFather 2. A Conciliation Conference was held on May 7, 2002, with the following individuals in attendance. The Father, Christopher A. Shrawder, with his counsel, Thomas S. Diehl, Esquire, and the Mother, Desma M. Shrawder, with her counsel, Jennifer L. Frechette, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date l71d y{ Jnc.lO ~~ Dawn S. Sunday, Esquire ~ Custody Conciliator _YX,. ~- ~,' ^~ '",' , - "" ., ~,-- -- < ~~ , , ~-"' '.0 ,~ '~, "-~~ - " '"".-<~-< ,-" - .. < ,",".',,,--, ...,., '~" " ~~ -== ~ - 0 t::,,} C) ig. C f....... -~1 0 ?' ,~ .;~~ .".! ~ () LJtX; '-...- q; rnrn ---:i~) z~. Zr- 1 ~~X OJ ~ 0- !;=f,:..) \::' ....-'- j' ~~, ~I.: - ()' ~~3 -~-~ ~'7(-) ?J t p:j :Pc: r..:? (jr-/"1 -:;--~ :c; ~ ~ :D ...J -< r- .. ~ ~ (~ , ,~rD1l'" , ,"'" ,_~L ",..,,,,~~_".,~.w,,,~,,,~V~JI!i'!1Wc-Hm~f",'ifC',i!!i'(':;~t'~tjN!~ffi'j~.,":""""",,,,'l!!~lIi$!f~ v/ NOV 1 0 Z003 W '"' , CHRISTOPHER A. SHRA WDER, Plaintiff * · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA * vs. * * NO. 2001-3287 DESMA M. SHRA WDER, Defendant . . CIVIL ACTION - LAW IN DIVORCE ORDER AND NOW, this I'r day of AI..-6v , 2003, the within Petition is granted. The Petitioner, Jennifer L. Frechette, Esquire, is permitted to withdraw her appearance of record for the Defendant in the above matter, and it is further ORDERED and DECREED that the Prothonotary shall so mark the record. BY THE COURT: pJ J. .~~ ~~~O~ ~' \\' \ ',~,"''''''' ~~-" 1I!IVl _~ ~ ,,< ---"," ~ _,>C_ """ i i1 '.w - 1lj,,~!F,!'I', '- -, ~~.~" > ,. " ~ VIl\'\f!ilJ.,Si!N3d A1NnO:; ("" )i":J:";j:{\lflO 01 :(1 HI! i1 I\ON !U'"'l(:' " r\Q\f_.~,1 , 1_', !_,,,;~'~!!l!~~~;!M~-fi""~:wr':'?-'~"."_f','-",""'.c'-!II\i'<"'r"ii~',,~~1/i~~ '1"'~~_~ " , CHRISTOPHER A. SHRA WDER, . IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLANDCOUNTY,PENNSYLV ANIA * vs. * NO. 2001-3287 * DESMA M. SHRA WDER, * CIVIL ACTION - LAW Defendant * IN DIVORCE PETITION TO MAKE RULE ABSOLUTE AND NOW comes the Petitioner, Jennifer L. Frechette, Esquire, and petitions this Honorable Court as follows: I. On or about July 23, 2003, the Petitioner, Jennifer L. Frechette, Esquire, did file a Petition to Withdraw Appearance, along with a Rule to Show Cause. 2. On August 5, 2003, the Honorable Kevin A. Hess did issue a Rule to Show Cause to show cause why Jennifer L. Frechette, Esquire, should not be permitted to withdraw as counsel for Defendant, with said Rule returnable twenty (20) days from service. 3. On or about August 11,2003, Petitioner did cause to have served upon Defendant the above referenced Rule to Show Cause. 4. On or about August 11,2003, the Petitioner did cause to have served upon counsel for Plaintiff, Thomas S. Diehl, Esquire, the above referenced Rule to Show Cause. 5. To date there has been no response from either party to the above referenced Rule to Show Cause. '-''ff~~ ,"="""c _~~~'C-;" _ -/" <, , WHEREFORE, the Petitioner respectfully requests that this Honorable Court grant the Petitioner leave to withdraw her appearance for the Defendant in this action. Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO, P.C. Date:\\.l\ .O~ Jennifi . Frechette, squire 130 West Church Street, Suite 100 Dillsburg, P A 17019 (717) 432-9666 ill #87445 ',1)1' '-', ,,, c " ,,' ~ - , ,,'~ , " , CHRISTOPHER A. SHRA WDER, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY, * PENNSYLVANIA * vs. * NO. 2001-3287 * DESMA M. SHRA WDER, . CIVIL ACTION - LAW Defendant * IN DIVORCE CERTIFICATE OF SERVICE I, Sherie A. Minich, legal assistant to Jennifer L. Frechette, Esquire, hereby certify that I served a true and correct copy of a Petition to Make Rule Absolute upon Plaintiff and counsel for Defendant, by depositing same in the United States Mail, Dillsburg, postage prepaid, addressed as follows: Desma M. Shrawder 61 Gasoline Alley Carlisle, PA 17013 Thomas Diehl, Esquire One West High Street Suite 208 Carlisle, P A 17013 Date: i//1/Q3 jLJi~ () ~JJzA "8herie A. Minich "":1[;, ~ ,",L_ ''''', I' - " !I ,I .,'"j , , , , :i 'i !I :-1 ,I '; : ~ '''I ::: ~ .,] -~I ~ !li!l<'JOOli"'lW". _ ,,,,.l!i~~1~!lI!!9WI~~j!IJ~>,1.j1";s.1,1!P';::"'"(>!"-',i<r%V"'- " (') 0 0 c: W -n :s:: z ::;:1 v'CrJ => n"1rT: -.-.r:: --... --n z_=:/ 11p 63,~;~ ! --~1 'T' -<.--,- C1' ,~~ r;::C.i ..." -r"TI ;tOe :J;: (:) :0 ~Fj 0070 1>'> om z -, ::;! :".) 55 0 -< ',;;,. "l"'~'!"'Y"!""'T~"'l!'!l1\ttr!'l';m-~:;''f:1f'j'Wl~''''R'I!~$('~,,_,,''i'\;'''I'l'J!~'~ 11 '. \ CHRISTOPHER A. SHRA WDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-3287 CIVIL TERM DESMA M. SHRA WDER, Defendant : CIVIL ACTION - LAW : 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 g 33tl1(...) 330l(d) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on June 4, 2001 by Certified mail, restricted delivery to Defendant, Desma M. Shrawder. 3. (Complete either paragraph (a), or (b).) (a) Date of execution of the Affidavit of Consent required by g 330l(c) of the Divorce Code: by the Plaintiff: ; by the Defendant: (b) (1) Date of execution ofthe Plaintiff's Affidavit required by g 3301(d) of the Divorce Code: June 19,2003. (2) Date of service of the Plaintiff's Affidavit upon the Defendant: August 2, 2003 by certified mail to Defendant, Desma M. Shrawder. 4. Related claims pending: None. 5. (Complete either (a) or (b); (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and a copy of which is attached: September 6, 2003 by certified mail, restricted delivery to Defendant, Desma M. Shrawder. (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by g 330l(c) of the Divorce Code: b intiff: ; by the Defendant: Tho . Diehl, Esqui e mey for Plaintiff Date: October 19,2003 - . \ _?,"~" _'C '."~ c, ~ '"' CHRISTOPHER A. SHRA WDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-3287 CIVIL TERM DESMA M. SHRA WDER, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE TO: DESMA M. SHRA WDER, DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the S 330l(d) affidavit. Therefore, on or after September 15, 2003, the other party can request the Court to enter a Final Decree in Divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a Final Decree in Divorce. A counter-affidavit which you may file with the Prothonotary of the Court is attached to this notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the tight to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CONNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Pennsylvania Bar Association Lawyer Referral Service 1-(800) 692-7375 (PA only) or (717) 238-6715 " =, "~1'" _, _, " ''f'_ . -", . -$,c{j-, ITi11'<!' ...,i'!'!I!~ _~___IIII'~" ~, ~~- .<-" <,,' _ "'" ~o.- -, ,-"'_ _ - ~~ - ,>, _ ._= . 0 __",~~., ,... " D (,: , <:.) --- 'Co) -~ fj ~1-'j1~" :":) ~Ir ;:-) --f ..= j',.) < 171 (j)-,- (:;:) r-, -< ;s -, C,,) <:-. -) i:~ "" j:---; , rn , , :-'.) ::;~ -( en ':(,:1 - rrl[~~\<tIR~~'~~'''''*'~'li'RW.~~~,,~ _",~~!@tI1~~,~JJ~,~~~?,- p, PENNA. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS QFCUMBERLAND COUNTY STATE OF . CHRiSTOPHER A. SHRAWD , Plaintiff . VEFlS,US . O~~~AVYpER. Defendant . AND NOW, No. OECREEIN DIVORCE 2001-3287 Otlzlk ;! z,'" ,btO"j, IT IS ORDERED AND DECREED THAT CHRISTOPHER A. SHRAWDER , PLAINTIFF, AND DESMA M. SHRAWDER , DEFENDANT, ARE; D,lVOflCEO FROM THE BONDS OF MATRIMONY, THE COURT RE;TAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAIsE;!;l QF Re:C;;ORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NQI')I~c . ,,,"', >;-"~-"'-_".'J; -", ")'j- ','~.'1,~'r;, "", ":"' : " ' ;.,,- .. '" I - '~1 ,- , , - " " By THE COURT: . / . ~ Pt.-. "'". -" ''',.,--,' PROTHONOTARY . . 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