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HomeMy WebLinkAbout01-054627 if • k A LARRY E. T[ JMPER; IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW TERESA D. J[JMPER, Defendant NO.O1-5462 CIVIL TERM ORDER OF COURT AND NOW, this 20`t' day of January, 2005, upon consideration of Defendant's Petition for Contempt, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within at a hearing scheduled for Thursday, March 31, 2005, at 2:30 p.m., in Courtroom No. 2, Cumberland County Courthouse, Carlisle, Pennsylvania. J Andrew Spears, Esq. 3211 North Front Street Harrisburg, PA 17110 Attorney for Plaintiff ,/Karl E. Romingcr, Esq. 155 South Hanover Street Carlisle, PA 17013 Attorney for Defendant i' o~ ~ ~5 :rc BY THE COURT, o i~eai2Yar - 7®ss ~ w,n,xeme a a-~sa~. a ~e - - ~- ~~ ~j , i A 1 ~ `i9~ l~~l~! 1 I.'~..ld ~.~f ~~~1 _~, ~.1 l~J"1.~ L ~ u~ x LARRY E. JUMPER, Plaintiff v. TERESA D. JUMPER, Defendant .- ` ' JA,N . 9 2005~(Y IN THE COURT OF COMMON OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2001-5462 IN DIVORCE RULE TO SHOW CAUSE AND NOW, this day of ,upon consideration of the foregoing petition, it is hereby ordered that ^ 1. A rule is issued upon the respondent to show cause why the petitioner is not entitled to the relief requested; - ^2. The respondent shall file an answer to the petition within 20 days of service upon the respondent; ^3. The petition shall be decided under Pa. R.C.P. No. 206.7 ^4. Depositions shall be completed within days of this date; ^ 5. Argument shall be held on in Courtroom _ of the County Courthouse; and ^ 6. Notice of the entry of this order shall be provided to all parties by the petitioner. BY THE COURT: J. LARRY E. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. TERESA D. JUMPER, : N0.2001-5462 Defendant : IN DIVORCE PETITION FOIi CONTEMPT AND NOW, comes Defendant, Teresa D. Jumper, by and through her attorney, Karl E. Rominger, Esquire and moves this Honorable Court to enforce the Marital Settlement Agreement. 1. The Petitioner is Teresa D. Jumper, who resides at, P.O. box 1096, Carlisle Pa, 17013. 2. Respondent is Larry E. Jumper, who resides at, 102 Longview Drive, Shippensburg Pa, 17257. 3. On April 7, 2003, both the Petitioner and Respondent signed the following Marital Settlement Agreement. A true and correct copy of that Order is attached as Exhibit "A." 4. Since the signing of said Marital Settlement Agreement, The Respondent has willfully failed to obey said agreement as follows: (A) Respondent failed to transfer to Petitioner the Neon automobile, sub-paragraph 4, page 4 of the Marital Settlemem Agreement. (B.) Respondent failed to pay alimony in the amount of 3,000 dollars, said amount to be paid in monthly installments of 250 dollars a month, also in sub-paragraph 4, page 4. (C.) Respondent failed to pay all outstanding medical bills as highlighted on Schedule -M- attached. (D.) Respondent failed to pay uncovered medical bills in full amount due, in sub-paragraph 6, page 6 of the Marital Settlement Agreement. 7. On July 24, 2003, the Honorable Court entered the following Decree in Divorce, Civil Action: 200Il -05462 between the Petitioner and Respondent. A true and correct copy of that Decree in Divorce is attached as Exhibit "B." 8. Due to Respondents failure to comply with both the Order and Marriage Settlement Agreement, Respondent should be responsible for all Petitioners attorney and court fees. WHEREFORE, Petitioner respectfully requests this Honorable Court to adjudge the Respondent in contempt of Court, and require him to comply with the Marital Settlement Agreement. Dated: January 12, 2005 Karl . Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant ~. ,. _ . , - R. LARRY E. BUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. TERESA D. JUMPER, : NO. 2001-5462 Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Teresa D. Jumper, do hereby certify that I this day served a copy of the Petition to Contemptupon the followitig by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Andrew Spears, Esquire METZGER WICKERSHAM 3211 North Front Street Harrisburg, Pa 17110 ~- -~. art E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 (717)241-6070 Supreme Court ID # 81924 Attorney for Defendant Dated: January 11, 2005 LARRY E. JUMPER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. TERESA D. JUMPER, Defendant N0.2001-5462 IN DIVORCE VERIFICATION I verify that the statements made in this petition aze true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unsworn falsification to authorities. Dater ,~/Z~L~- l~ GCJI Teresa Jumper N 0 ~ ~ ` C..- "~" ..:. , n' r {_` ~ vP _an~ ~- t>j ' -- 'Z'. [> ~~~ s- <<jn =' ~ '~ `- _ .. ' ~_ -;? N v~ EXHIBIT A _ .~ _ ,... r LARRY E. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. r, .-, TERESA D. JUMPER, : N0.2001-5462 - Defendant : IN DIVORCE _ ,_, MARITAL SETTLEMENT AGREEMENT AGREEMENT, made this ~ day of V~ , 2003, between Teresa D. Jumper (hereinafter called "Wife") and Larry E. Jumper (hereinafter called "Husband"). WITNESSETH: Diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto desire to settle fully and finally their respective financial and property rights and obligations as between each other, including without limitation: (1) the settling of all matters between them relating to the ownership of real and personal property; (2) the settling of all matters between them relating to the past, present and future support and/or maintenance of Wife by Husband and of Husband by Wife; (3); and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: ~- ~~ ~ ~ ~ i r '~~ 1. AGREEMENT NOT PREDICATED UPON DIVORCE It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for the institution, prosecution, defense or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds, nor to prevent either party from defending any such action which may, has been, or shall be instituted by the other party, or from making any just or proper defense thereto. The parties further agree that they will each sign the Affidavit of Consent and Waiver of Notice after the required ninety (90) day time period has elapsed when such a divorce procedure is instituted. 2. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Karl E. Rominger, Esquire, for Wife, and Andrew J. Spears, Esquire, for Husband. Each party acknowledges that she or he has received independent legal advice from counsel of her or his selection and that each fully understands the facts and has been fully informed as to her or his legal rights and obligations and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 2 Wife and Husband may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if she or he were unmarried. Each may reside at such place or places as she or he may select. Each may, for her or his separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to her or him may seem advisable. This provision shall not be taken, however, to be an admission on the part of either Wife or Husband of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with her or him. 4. PERSONAL PROPERTY Wife and Husband do hereby acknowledge they have heretofore divided the marital property, including, but without limitation, jewelry, clothes, furniture and other personalty, and hereafter, Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and, Husband agrees that all property in the possession of Wife shall be the sole and separate property of Wife. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, she or he may have with respect to any of the above items which are the sole and separate property of the other. Husband agrees to transfer to Wife upon execution of this Agreement, without further consideration and free and clear of all liens and encumbrances: x ~: r 1. Husband shall transfer to Wife the Neon automobile free and clear of all liens and encumbrazices. 2. Husband shall pay alimony in the amount of $3,000.00, said amounts to be paid in installments of $250.00 per month. 5. TAX RETURNS Husband and Wife agree to file sepazate returns from hereinafter. Husband shall pay all amounts do and owing form any and all past marital returns. Further, Husband shall indemnify wife against any penalty or interest for any tax due and owing as of the signing of this agreement. Husband further agrees that he will be responsible and hold Wife harmless for any contingent liabilities on joint income tax returns previously filed by the parties and will agree to pay any claim or expenses azising out of such returns or liabilities. ~s U/ i and agrees to %~ 4 /s ~, 6. MEDICAL INSURANCE P4y .Gu ac,ts ~-a~,d,'~y .!h.ecr°~'c ~~ ~%/~s ~~ sc ~c~ ~I115 t t_ _L„11 L .. :.......... A L •/ 4 /~r 7Lo ~~(/P ~~iiC/!~ B~i l~CC1' 7~~ S~6 ni ~ Cvverl9ll ~ v1~c~~ ~-r(/ rl4y ~G(! ~ ~o~~r t o~~e. 7. LIABILITIES Wife and Husband each covenant, warrant and represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other prior to or after the effective date of this Agreement, except as may be otherwise provided by the terms of this Agreement. 4 $. NO BAR TO FURTHER PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available. It is agreed that this Agreement shall not be impaired by any divorce decree which may be granted but shall continue in full force and effect notwithstanding the granting of any such decree. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. 9. MUTUAL RELEASE Wife and Husband each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights; titles and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, {b) any State, Commonwealth or territory of the United States, or (c) any other country, or any rights which Wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marihal relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Wife and Husband to give to each other by the execution of this Agreement a full, complete and general release with respect to any and al] property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein above. 10. OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith (and within at least thirty (30) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectually the terms of this Agreement. 11. SUCCESSORS' RIGHTS AND LIABILITIES This Agreement shall, except as otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or assigns. 12. ENTIRE AGREEMENT Wife and Husband do hereby covenant and warrant that this Agreement contains all of the representations, promises and agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there aze no claims, promises or representations not herein contained, either oral or written, which shall or may be charged or enforced or enforceable unless reduced to writing and signed by both of the parties hereto; and the waiver of any term, condition, clause or provision of this Agreement shall in no way be deemed to be considered a waiver of any other term, condition, clause or provision of this Agreement. 13. BINDING EFFECT OF AGREEMENT This Agreement shall remain in full force and effect unless and until terminated pursuant to the terms of this Agreement. -The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 14. SEVERABILITY If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law, or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 15. HEADINGS Any headings preceding the text of the several paragraphs and subparagraphs hereof aze inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meanings, construction or effect. 16. EFFECTIVE DATE The effective date of this Agreement shall be the date upon which it is executed; however, the transfer of the property provided for herein shall only take place upon the entry of a final decree in divorce, unless otherwise indicated. The support provisions of this Agreement shall take effect as indicated. Notwithstanding the foregoing, if a final decree in divorce shall not have been obtained within four (4) months from the date of execution of this Agreement, this Agreement shall be null and void. 8 17. CONTROLLING LAW This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and yeaz first above written. This Agreement is executed in duplicate, and in counterparts, and Wife and Husband, as parties hereto, acknowledge the receipt of a duly executed cop :hereof. i ~ Witness ~ eresa D. Jumper/WiF Witness Larry E. Jumper/Husband 9 ~- se l~ ~~/~~e /~ -- _ ___. __. _ _ . . a~~ l ~r .ao~ _ __ _ . _ _... __ ... _ ._. _ Main}OFF NCirrte' I~_eres~ ~.,. J~m~e~ _ ._ ..__ l~e~e,-~elo.nl N(~r~_. Larr C___J.ump~e-__~r ._. _ _ _... D_~cket._Numbe~- ;_. U.UZ.._~...5...~_Cj~j._.._ ... __ w ~f~CSCS.C~Se_.N._um~,e~-_-_ ._3y_y_.~~~~~-4. ... ...... _.. . _ _ _ _.. _. . ~~l.lo~,uir~c~ b~~~~ f~S b~~.n . 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(7L4kiiNh QA'r6 '4"Ei2ESA dUMPEk P.d. k4{17: 1094 G•~ARLISLEi, PA 17q:9.3~-bg9ls I(rdElrr,I!(r~orrallr~llrrlBrrlLralrirrriLJJr~rlLrr~lr!! v3r5o t#i•1u9 ii%34 Qa 4a Y5 EL Yi1I. 9. rr rr irron~ir~'TATENf Et~1T 73.7-789-4szs from 8 At9 to 5 PM VI5r7/MASTERCACdD ACCEPTED ~__I CNECK FiEAE Ear Crs-,rit Caed Paymeri :~Eto4^a amot.rav Q~ 243786 O1 18.00 Y(:R1f9 ld;iSiUia i' PIl~M1flBE(-7 F7lfiE NO. NE~V P.hL.ANCG tARlC HMA 1'4iY5 MGl7'TrCEN~T PEN 1104 MOUNTdR RD LdYSVIILE, PA 17047-92gq I~rJllrrdlf~~,rirrllr,ellrLrrJ,(I1rroClrrrBLsrrlrol,ll,r! PLcl1SE RE•T'Uf?N THIS PC;ri7'I{9t^7 WIThE °il'tPo3Eh~l' P;i7CE, C'drargzs and paymenrt~,; noS ~ap~aring (xr khi, ~;tetement mh appear an next r+,~ntt,'s statement. ,. Cansnlidafed Callectio~~ Ser~~lce, Cite. _. _.. _-_.~ °°- P.C1. ~3cYx fi~355C9IIxrrisk~urg. k'.Q E'13,4fi .. (717) ta52-8641 i (BfICD) 521-'755 5'I'ATE~~~N'~` uo~~fue~0~nnn{fu{~eiile~e~ae~io0~ie{eel~~oa centoCeiet~ -: f __~_:.I :... DETACH HER[ AND ~RETURPJ dpP PORY'70N UiTH YOUR FAYPtF:NT Jon Barry 8~ Associates, Inc. 216LePhillip Ct • Concord NC 28025-2954 (888) 466-9634 Date: March 14, 2003 Account#: 3339699 RE: Teresa D Jumper Creditors: Carlisle Regional Medical 30.57 Total: $30.57 AMERICAN CO[.(.ECTORS association member NOTIFICATION OF ASSIGNMENT Your account(s) has been placed with this office for collection. Please mail the balance owed, or contact our office. This account may be reported to all three credit reporting agencies after 45 days if payment in full is not received. 00 $25.00 Service chazge on all returned checks 00 Please use return envelope for all coaespondence Debt Collectors Since 1986 Please Call: (888) 466-9634- Control No.: 9232784 This is an attempt to collect a debt and any information obtained will be used for that purpose. Unless you notify this office within 30 days that yoti dispute the validity of this debt or any portion thereof, this office will assume this debt is valid. 1f you notify this office in writing within 30 days of this notice, this office will: obtain verification of the debt or obtain a copy of a judgment and mail you a copy of such judgment or verification. If you request this office in writing within 30 days after receiving this notice, this office will provide you with the name and address of the original creditor, if different from the current creditor. If you wish to pay by VISA or MasterCard, fill in the information below and retum the entire letter to us. Account Number - Payment Amount ExpirationDa[e Cazd Holder Name Signature of Cazd Holder Date March 14, 2003 '~ JON BARRY & ASSOCIATES INC PO Box 748 Concord NC 28026-0784 #BWNHRMD 250238 29717 #0314 0834 0029 7179# 3339699-26 indilodlluuullulluliulludduJiuldmlluuldi Tessa D Jumper PO Box 1096 Cazlisie PA 17013-6096 luhlluhlluu~lrhllu liuilu~ilnl nlnhlnlluiuulil Account#:3339699 Balance Due: $30.57 ~., _ .., ~,~ Wilson St. Internal Medicine 2~0 Wilson Street Carlisle, PA 17013 ADDRESS SERVICE REQUESTED TERESAJUMPER PO BOX 1096 CARLISLE, PA 17013 wsim Statement Date Chart Number Page 0210di2003 JUMTi9)00 Make Checks Payable and Send To: Wilson St. Internal Medicine -220 Wilson Street Carlisle, PA 17013 Amount Enclosed $ Check # -1 ** THIS BILL WAS PREPARED BY ACCUMED BlLLMG. ** FOR ALL BILLING QUESTIONS PLEASE CALL 717-702-5500. please cut on dotted Tine and return top portion w ithyayrrent-------------------------------_-~--__ Balance Forward From Previous Statement 0.00 Patient: TERESA JUMPER Case Descrip: $15 PTS RESPONSIBILITY Amount Paid by Amount Paid By Dates Procedure Procedure Description Charge Insurance Guarantor Adjustments Remainder 11104!02 99213 EST PT LEVEL III OFFICE VISIT 54.00 -37.06 0.00 -2.00 15.00 Past Due Please Pay Immediately! ** All charges are billed to the appropriate insurance carrier before you are billed. This balance is now the patient's responsibility. Payment is due within 20 days from the statement date. We Thank You for payingyouraccountpromptlyl Wilson St. Internal Medicine 11/25/2002 Amount Due 15.00 ~~ vv.as'.+v.wxrmvvr+rvnxv...:+a-t.r:laIlyNS1H2.:AJ4Yv.51vSVA'3tiuW.vtis:e'...arv-xtil:..:~?::mw'rc:S.'CST.:.~:.:....~'~.:.:5'L:.:iA:IE:..r..T:.d'.ni-~w Pinnacle Health Hospitals en•.,••a •••. .:?W.&~.dL~i'E[~g!nY-LF9RS°i~.^.d~2:~p.'.'A~'aYsNRSaFS L'A~fi9~3'xf° _.. Aa.c:_.iT_a ".e'.C-?,'.~~`:- P O. BOX 2353 HARRISBURG, PA 17105 (717) 230-3717 ror Account Information, Please Call (717) 230-3717 u xuaacuen~vase ~ uescnpaon Amount PREVIOUS BALANCE .00 12/16/02 1 EMER MED VISIT III P/F99283 133.00 12/16/02 1 EMER MED VISIT III P/F99283 133.00 12/16/02 1 EMER MED VISIT III P/F99283 133.00- 12/16/02 1 EMER MED VISIT III P/F99283 133.00- 12: 16/0'< "' - "1 EMER M~-A-VI9IT -III P/F99283 -' - 133:00 12/16/02 1 EMER MED VISIT III * .00 12/16/02 1 EMER MED VISIT III ~ .00 12/16/02 1 EMER MED VISIT III * .00 12/16/02- 1 EMER MED VISIT III * .00 12/16!02 1 EMER MED VISIT III ~ .00 12/16/02 1 VISIT LEVEL 1 E 99281 88.00 12/16/02 1 PROMETH 25MG AMP J2550 7.30 12/16/02 1 PROMETH 25MG AMP J2550 7.30- 12/16/02 2 MS 2MG SYR. J2270 14.00 12/16/02 2 MS 2MG SYR J2270 14.00- 12/21/02 BLUE CROSS DISCOUNT 112.71- 02/14/03 BLUE CROSS DISCOUNT B55 BLUE CROSS 36 112.71- 02/21/03 BLUE CROSS DISCOUNT B55 BLUE CROSS 36 112.71 02/26/03 PMT-CBC 65 SPEC B55 BLUE CROSS 36 97.46- 10.83 YOUR ACCOUNT IS PAST DUE! PLEASE CALL OR PAY IMMEDIATELY. CUSTOMER SERVICE HOURS MON WED-FR17;OOAM TO 4:OOPM TUES-THUR 7:OOAM TO 6:OOPM CALL 717-230-3717 LOCAL OR 1-800-603-6064 OUT OF AREA PINNACLE HEALTH HOSPITALS P.O. BOX 2353 ' HARRISBURG, PA 17105 ADDRESS SERVICE REQUESTED ~u if ~~u r~~~ nu u~)n~~u{~u~~us~s~ us~(u~s{i u~~w~~ i~~ 00005763 1 AT 0.292 O1 223446888 THERESA D JUMPER PO BOX 1096 CARLISLE PA 17013-6096 ADM DT: 121602 DSH DT: 'NONE" HOSP SVC: HER DX CD: 789.09 223446888 JUMPER Vlsa ~ Mu@raN ~ Discover ~ Amarlrrn Express Make Check Payable To PINNACLE HEALTH HOSPITALS PINNACLE .HEALTH HOSPITALS P:O. BOX 2353 HARRISBURG, PA 17105-2353 Please check this box if your address or insurance information has changed and record the changes on the back of this statement COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) On this, the ,! 1 ~~ day of /'~j ; ' ~ , 2003, before me, the subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of ~.y~ i Cumberland, personally appeared / C!f'f>'i?r L~ , ;' ~ ~ d n Lrf~and in due form of law acknowledged the above Agreement to be her act and deed and desired the same to be recorded as such. r i ~ ~ ".r /" Lintle J. JwnF.~, Ntriary f'u~sc Cersslet3oro, Cumberland County MY Commission Expires Jtly E3. zoos • PemayN~ea Associaypi Ot hbfaries COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND On this, the % ~ ~ day of /~~~ i ~ , 2003, before me, the subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of Cumberland, personally appeared ~t.zer r ,,T~,„.=>; y~ and in due form of law acknowledged the above Agreement to be his act and deed and desired the same to be recorded as such. ~~ / , NOTARIAL SEAL CAROL A. LYTER, Notary Public City of Nantebtug, Deu(~Itin County My Commission Expges Dee. 23, 2iJ04 10 ~ , J Plaintiff Defendant IN DIVORCE AFFIDAVIT OF CONSENT ., ,. ~, 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on-: LARRY E. JUMPER, v. TERESA D. JUMPER, September 19, 2001, and served upon Defendant on October 5, 2001. Affidavit of Service filed,_ December 6, 2001. :: .-~ 1~ (~) '~ 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days ha5e elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Dated: ~(~ - C7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2001-5462 Teresa D. Jumper Document #: 166455. l ._ .` LARRY E. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW N0.2001-5462 TERESA D. JUMPER, Defendant INDIVORCE ,- •. o .... -n AFFIDAVIT OF CONSENT •.> 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code-was filed om ~. " ~, September 19, 2001, and served upon Defendant on October 5, 2001. Affidavit of Service filed=~ ~w December 6, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Dated: ~} - 1 ~ - ~~ 3 (' ~A~r2C;~ f/ ~ll;rYl~.t'~ Teresa D. Jumper Document N: 266d55J EXHIBIT B .~~~..,. In The Court Of Common Pleas Of ~ Cumberland County Prothonotary~s Office J Civil Action No.: 2001-0562 JUMPER TERESA D 102 LONGVIEW DRIVE SHIPPENSBURG PA 17257 JUMPER LARRY E JR Plaintiff ** VERSUS ** JUMPER TERESA D Defendant You are hereby notified that a Decree in Divorce was entered in the above captioned case on July 24, 2003. This letter should not be used in place of the actual Decree. If you desire a certified copy of this Decree, you can obtain the same by coming into our office. Please bring this letter with you. The fee is 9.00 cash or money order. If request is made by mail, please enclose $9.00 for the certified copy of Decree. Also, do not forget to indicate Civil Action No. on your request. Sin ely yours, ~w"~ t Prothonotary,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LARRY E. JUMPER Plaintiff NO. VERSUS TERESA D. JUMPER, Defendant DECREE IN DIVORCE AIVD NOW, N Jt ~1 ~ l T+OO,~, IT IS ORDERED AND DECREED THAT Larry E. Jumper ,PLAINTIFF, AND Teresa. D. Jumper ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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; BY THE COU HONOTARY >~ [":1 .-f ~fi 'rt ___ ~' ~~ _ --f ,`17 r_ ;= _ J ~_ w... .., C -_ -Iii ,e: p~J -_ ~ C LARRY E. JUMPER, : IN THE COURT OF COMMON OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. : NO.2001-5462 TERESA D. JUMPER, Defendant : IN DIVORCE AMENDMENT TO PETITION FOR CONTEMPT Petitioner, by and through her attorney Karl Rominger Esquire, respectfully represents and moves this court as follows; 1. Petitioner is Teresa Jumper, who currerrtly resides at 25 South Pitt St, Carlisle Pa 17013. 2. Respondent is Larry Jumper, who currently resides at 102 Longview Drive, Shippensburg Pa, 17257. 3. A Petition for Contempt was filed to the above term and number on January 14, 7.005. 4. The Petition, as filed, coirtained paragraph 4 (a) which stated that the respondent failed to transfer to Petitioner a neon automobile. 5. This paragraph was in error as Respondent did transfer title pursuant to the Marriage Settlemem Agreement. 6. Pursuant to the Pa. Rules of Civil Procedure Petitioner hereby amends the petition to reflect this fact. ..,~~ _ d . „~ WHEREFORE, Petitioner respectfully amends her Petition for Contempt. Respectfully Submitted, Kazl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 (717)241-6070 Supreme Court ID # 81924 Attorney for Defendant se.-a......,t. igM ~'- _ _ _ _ _ _L. _ _ '_, f„ t i LARRY E. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. TERESA D. JUMPER, : NO. 2001-5462 Defendam : IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Teresa D. Jumper, do hereby certify that I this day served a copy of the Amendment to Petition for Contempt upon the following by depositing same in the United States Mail, first class postage prepaid, at Cazlisle, Pennsylvania, addressed as follows: Andrew Speazs, Esquire METZGER WICKERSHAM 3211 North Front Street Harrisburg, Pa 17110 Respectfully Submitted, ROMJ~TGER, BAYLEY & WHARF Kazl E. Rominger, Esquire 155 South Hanover Street Cazlisle, Pa 17013 (717)241-6070 Supreme Court ID # 81924 Attorney for Defendant Dated: January 18, 2005 ~~: ~` O r }n~ N ~~ LARRY E. JUMPER, Plaintiff IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. TERESA D. JUMPER, Defendant N0.2001-5462 IN DIVORCE MARITAL SETTLEMENT AGREEMENT _ . ,~ ;,, AGREEMENT, made this ~ day of Vi , 2003, between Teresa D. Jumper (hereinafter called "Wife") and Larry E. Jumper (hereinafter called "Husband"). WITNESSETH: Diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto desire to settle fully and finally their respective fmancial and property rights and obligations as between each other, including without limitation: (1) the settling of all matters between them relating to the ownership of real and personal property; (2) the settling of all matters between them relating to the past, present and future support and/or maintenance of Wife by Husband and of Husband by Wife; (3); and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: r: . ,3.3F oS PCtC1 1. AGREEMENT NOT PREDICATED UPON DIVORCE It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for the institution, prosecution, defense or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds, nor to prevent either party from defending any such action which may, has been, or shall be instituted by the other party, or from making any just or proper defense thereto. The parties further agree that they will each sign the Affidavit of Consent and Waiver of Notice after the required ninety (90) day time period has elapsed when such a divorce procedure is instituted. 2. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Karl E. Rominger, Esquire, for Wife, and Andrew J. Spears, Esquire, for Husband. Each party acknowledges that she or he has received independent legal advice from counsel of her or his selection and that each fully understands the facts and has been fully informed as to her or his legal rights and obligations and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 3. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live sepazate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if she or he were unmarried. Each may reside at such place or places as she or he may select. Each may, for her or his separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to her or him may seem advisable. This provision shall not be taken, however, to be an admission on the part of either Wife or Husband of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart. Wife and Husband shall not molest, hazass, disturb or maiign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with her or him. 4. PERSONAL PROPERTY Wife and Husband do hereby acknowledge they have heretofore divided the marital property, including, but without limitation, jewelry, clothes, furniture and other personalty, and hereafter, Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and, Husband agrees that all property in the possession of Wife shall be the sole and separate property of Wife. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, she or he may have with respect to any of the above items which aze the sole and separate property of the other. Husband agrees to transfer to Wife upon execution of this Agreement, without further consideration and free and clear of all liens and encumbrances: ~ r 1. Husband shall transfer to Wife the Neon automobile free and clear of all liens and encumbrances. 2. Husband shall pay alimony in the amount of $3,000.00, said amounts to be paid in installments of $250.00 per month. 5. TAX RETURNS Husband and Wife agree to file separate returns from hereinafter. Husband shall pay all amounts do and owing form any and all past marital returns. Further, Husband shall indemnify wife against any penalty or interest for any tax due and owing as of the signing of this agreement. Husband further agrees that he will be responsible and hold Wife harmless for any contingent liabilities on joint income tax returns previously filed by the parties and will agree to pay any claim or expenses arising out of such retums or liabilities. 6. MEDICAL INSURANCE p4y all ~utsf~.,d,~i ~,ec~~'c~~ ~%//s Husband agrees to W ~ fe ~ ~ecf f~ S~G.Y;~ t~e~ fo ~f~C S4; c%/ o~ c3/~~ C~~ss -~~_ ~~y!r~ir7: zf f~~y a~~ its ~- - - .. ~ ~oveweJ ~ uJ~~~ w~(~ rl4Y ~G(~ 4 nova t ~uC. 7. LIABILITIES Wife and Husband each covenant, warrant and represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other prior to or after the effective date of this Agreement, except as may be otherwise provided by the terms of this Agreement. 4 x.< 8. NO BAR TO FURTHER PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available. It is agreed that this Agreement shall not be impaired by any divorce decree which may be granted but shall continue in full force and effect notwithstanding the granting of any such decree. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. 9. MUTUAL RELEASE Wife and Husband each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether ~.v:: arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any other country., or any rights which Wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Wife and Husband to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may azise under this Agreement or for the breach of any thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein above. 10. OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith (and within at least thirty (30) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed .in order to carry out fully and effectually the terms of this Agreement. 11. SUCCESSORS' RIGHTS AND LIABILITIES This Agreement shall, except as otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or assigns. 12. ENTIRE AGREEMENT Wife and Husband do hereby covenant and warrant that this Agreement contains all of the representations, promises and agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there aze no claims, promises or representations not herein contained, either oral or written, which shall or maybe charged or enforced or enforceable unless reduced to writing and signed by both of the parties hereto; and the waiver of any term, condition, clause or provision of this Agreement shall in no way be deemed to be considered a waiver of any other term, condition, clause or provision of this Agreement. 13. BINDING EFFECT OF AGREEMENT This Agreement shall remain in full force and effect unless and until terminated pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 14. SEVERABILITY If any term, condition, clause or provision of this Agreement shall be determined or declazed to be void or invalid in law, or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the pazagraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 7 r 15. HEADINGS Any headings preceding the text of the several paragraphs and subpazagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meanings, construction or effect. 16. EFFECTIVE DATE The effective date of this Agreement shall be the date upon which it is executed; howevery the transfer of the property provided for herein shall only take place upon the entry of a final decree in divorce, unless otherwise indicated. The support provisions of this Agreement shall take effect as indicated. Notwithstanding the foregoing, if a final decree in divorce shall not have been obtained within four (4) months from the date of execution of this Agreement, this Agreement shall be null and void. 17. CONTROLLING LAW This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. This Agreement is executed in duplicate, and in counterparts, and Wife and Husband, as parties hereto, acknowledge the receipt of a duly executed cop hereof. Witness eresa D. Jumper/Wif ~~ ~~. ~l Witness Larry E. Jumper/Flusband • -T..J I - A . . PA TITLE NUMBER (AS SHOWN ON: TTACHED TTn.E) .:. F VEHICLE - M YEAR PURCHASE ' ~ ~ .~~'T ~ ) ~ t i - - ' ~ PRICE .. s ~ - ~ y , (See note an reve, e) • '. . x I C L F I H pE CA ~ ~ C Dm TKI N N U MB q - ~ ¢ ~' / 7 `y' o /, ~~ / / / j M '5U ~ - - ~ D ~ LEBS ~ , ./ O~. - . / 1~~ V t-llY -GOOD :i:~.FAIR. SPOOR.; TRADE IN f3 NAME ( R ` LL BUSINESS NAME) 1~~F~IR~S~ ~NAME '- MIDDLE INITIAL . n ~ ' .~ ,,, i '.i. J r ~~~ ~ ~~~ ~ TAXABLE '~ .. '. - . __ - ) . _ ~ /V.l LLLCCC .. M 1`- ` .. AMOUM ' . ~ H COSEL4ER ~ , 1. Sales Taz Due ' - ... ... z6%LO61w x 7%107) . - .: See note mrererse). • z L` LAS NAME (OR FULL BUSINESS NAM FlRSi NAME MIDD INITIAL r ,... r '/yam n p v' • I C {'- ..... l DA - ACQUIFED( P ~S~Ep~ ,r ' ~x¢~mpp 1.' E tpn r - Rgzsq<Cpde (IOU9t': be a Otl~ 7. r+ t - //'/~~(~ s' i cr ~3 - . ~ ` ^~~ { .z'.! ~ x CO-PURCHASER 1 Irst -t `. g„y,* tB Second AssynmeM ?i a 7 STRE )~ C COUNTY CODE G J(/ YYI .. ~~ ( ~ 2. Title Fee ~ . C STATE ~ ZIP C DE ~ ~ ~ ~ ~ ~ gEFEq m GduNTY CODES ~ ~ ~- / ^ ,~D DSTUIG ON REVERSE SIDE ' 3. Lien Fee OF PINKCO p LAST NAME (OR FULL BUSINESS NAME) ~ -FIRST NAME ~ ' MIDDLE INTIAL DATE ACQUIRED/ R ~ ~ ' ,. , , . p... t. PUFjCHASED . ~ u':: ~, : ' q eglstratwn or Q~ ' . - .. .. .. ~ . .. . - Pmcess,ng Fee ' ' e 6 CO-PURCHASER - ~ ~ ~a a ' ~ Bur n ~ "z'f t `~ ~ w ` , dM , R $, e- ~ : m u` ~ STREET COUNTY CODE Dupl cae eg. 5. ~ z ~ .< ~ .. : ,; ~1 '-.. ~ .. r: `.:. ,.. .-, .i v I _,_ G.; .:~; ~ F Na of Cabs • •: Q CRV : ~i ' _, - n . a.;STATE ' - , .> . ::PZIP CODE-.:.. _'~ , i REFER m COUNTY CODES :~ ..: ~ - ' DSTING ON PEVERSE 510E OF RNK COPY g, Transfer Fee - /~ E MAKE OF VEHICLE VEHICLE IDENRFlCATION NUMBER ' c ; - :. ' ~~ .i,a L; ! + ~ t,! !. ~ t Increase Fee . 7 s~ MODEL VEAA BODY TY PE (CP TK ETC) CONDITION _ ~ - .. - `^ GOOD ~^' ~ ~ ~ 9. Re e-nent .. FAIR POOR t F. ORIGINAL PLgTE. /:: Check Orls~ TRANSFER OF;PREVIOUSLV ISSUEDPLATE`: iit ". TOTAL PAID 9 ~70. - ~ ~ ~ ~ PLATE TO BE ISSUED BY - (Add 1 thru 81 ^ TRANSFER 8 RENEWAL OF PLATE • . BUREAU (PROOF OF IN- ' ~ TRANSFER 8 REPLACEMENT OF. PLATE .. Sand Qne .. _ - $URANCE MUST BE Aj- ' ' T ° - ~ ~ 71.GRAND TOTAL ..; Check in O TRANSFER OF PLATE&HEPLACEMENT OF STICKER"~'~ ' ' ' ^ ACHED) - ~ ~ (Add 9810) '"' '- This Amount "~' ~ ' ~ ~ - EXCHANGE PLATE TO BE' BUREAU t ISSUED BY ,.-,-.. _ 'REASON FOR REPLACEMENT..: - ~ ' I .. 1 ~:.. - - ' - - - ~ ~ . _ . '. I]LgST " i ~ ~ ' ~ ^ DEFACED "' ~ Q STOLEN ' ~ c ~ o ~ TEMPORARY PLATE ISSUED BY FULL AGENT EXPIRES ~NEV~ Ec8rv8D lLOST W MNU Monts fear f' NEVER DECEIVED bock Is checked a cent must co lets Form MV-44. N zo F „ _-' TRANSFERRED FROM TRIE NO. .. ' VIN ~ - _ , . E ~ ^ . - ~,,, ' ~. :.. ,., ~~r## fi~tt. . SIGNATURE OF PERSON FROM SIGN HERE - ~' ~ ' ' :.. .. . ... . : ~ $ • FA E NJ ~ ~ G J ~ ~ ~ RELATIONSHIP TO APPLICANT d .. , , . >l~.p~~*,.... . . : . T • PR ANr DIIF O TH A F ER C VEHICLERCHASED GVWR~ -~ UNLADEN WEIGH[" REQ REG: GROSS WT RED. REG. GROSS COMB WEI G PL I NF O INCLUDING LOAD WT. (IF q~PLK:ABtE) A P I C ~ ~ INSURANCE COMPPNV NAME POLICY NO. (OR POLICY EFFECTIVE POUCV EXPIRATION ATTACH BINDER) I DATE DATE E (P TN O. tCER[IFY THAT ON MOMH DAYYFAfj I G ISSUING ' ' - -.. , AGENT ~ I RAVE CHECKED TO DETERMINE THAT THE VEHICLE IS INSURED AND S •-.1' ..~ ;' INFOR- ;. ISSUED TEMPORARY REGISTRATION TO THE ABOVE APPLICANT, IN - I I G A ENT SIGNATURE . - ... ., C CAMPl1ANCE WITH ALL ~~~~ PROVISIONS OF THE VEHICLE CODE i / NATION WAND DEPARTMENT REGULATK)NS Ci I/WE CERTIFY THAT I/WE HAVE EXAMINED AND SIGNED THIS FORM AFTER ITS COMPLETION AND T THE INFORMATION GIVEN IS TRUE AND COR - IF AN E%EMPTK)N - IS CLAIMED, THE PURCHASER FUFmiER CERnFlES THAT HE/SHE IS AUTHORIZED TO CLAIM THIS EX PTION. I/, ACKNOWLEDGE THAT I/WE MAY LASE MV,/OUR OPERATING PRIVILEGE(S) OR VEHICLE REGISTRATION(S) FOfl FAILURE 10 MAINTAIN FlNANCIAL RESPONSIBILf[Y' ON THE CURRENTLY REGISTERED VEHICLE FOR THE PERIOD OF V BE SUBJECT TO A flNE NOT EXCEEDING $,,DOD AND 1 PPoSONMEM OF NOT MORE THAN TWO YEARS FOR PNY ~ N I ON THIS FORM NT THAT %WE MAK E STATE FALS z 2 f Fiat Purchaser w Si to tMdzed 6gner TELEPHONE NUMBER ' ' Sign re of Seller ~ .. F J ,ST jai ~loa (7i a m ASSIGN- Signatu of Co-Purchaser/T1t1 uthoriz Signer '. MEtJr ~ - 7 I d Signature of Co-Sell '. J : {i t ~ t' ~ /: ) N .. .. . ... ,.s'e. I .. ,,,. .. .; : { . . ,. - . 4. ~ Signature of Second Purchaser or Authorized Signer TELEPHONE NUMBF,R }'" ' ~.:. SlVnsture Di Seller - ' ~ 2ND -~ _. / (. ~ is ~, . .._ ~. t. .. ASSIGN- Si ~ nature of Co-PUrchaser/Tilla of Authorized SgneY. ~ MEM 9 Sgnature of Co-Seiler _. ,. H NOTE: If s co-purchase[ other.)haR. your Spous@ is listed and you want (tie title tp.be hsjed. as Joint,Tenanls With '~ i? owner title oeS to sti vl In o e GK )•I ~REI, ; Othe S~iseL.,Eha tine Fight of $urYiyq)'.Ship° (Ori death of olje F~~ - ' t , will be issued as "Tenants In Common" (On death of~one owrieY~, InteresPof decea's`eti~oWner goes to his/her Heirs or ° ' - estate).-:, -' NOTE: IF THE VEHICLE IS TO BE USED AS A DAILY RENAL OR LEASED VEHIG4E CHECK THI i BLOCK O •(IFl BLOCK IS CHECKED, COMPLETE AND gT7ACH FORM MV-IL. MtJStNOtN Nl,l)VItStH: ~-.., t~ Lebo's Garage LLC 301 North College st, Carlisle pa 17013 (717)-249-2977 July 16 2003 Mr. Larry Jumper Jr. On June 16, 2003 the Carlisle police department called us to Impound a 1999 Plymouth neon from the corner of pomfort & Bedford st. in Carlisle blue in color, because of a discrepancy of ownership. Driving the car was Teressa Jumper ,and having a passenger of Nicholas A. Miller, who claim that Teresa is the owner. Carlisle Police computer records show that you are the last registered owner of the vehicle, If this is incorrect please call us ASAP and let us know so we can change our records. The vehicle can not be released from impound till the tow bill and storage is paid in full and proper proof of ownership is shown to the Carlisle Police Department. Any other information you can provide would be greatly appreciated, Thank you very much for your time and cooperation in this matter. Thank you, Lebo's garage Larry Jumper Jr. 1021ongview dr. Shippensburg Pa. ~~ ~.~ ,. ~~o~s ~aRnGE~a towiMtgue N0 000352 aot x. coneyj,ljs~,~e c~~~ r~~ <»o'ia (~i» ~ ~.~ n»n ~4,.ezao DATE ~ TAIE .REQUESTED BY n~ PO.NO, NAME _ ~ R-~~ ~C,n7 ~2 ~ PHONE ADDRESS ~ ~a.~-ua~w 1~?K. clTV sTATE zl S~aPPe~-cS ~ LOCATKSN OFVEHICLE .~ s r -ar- E P o f -Sr. YEM.AUKE: L C,~ • ~ ~'o..c~ UGt STATE LIC. PLATE H0. VEHICLEL0. NQ REOISTEREDOWNER ~~$ IVNLEA6E SERVICE TIME EXTRA PERSON FINISH FINISH FINISH STMT START START TOTAL TOTAL TOTAL _ REASON FORTOW SPECUILEQIIIPENT ~, DACDIDENT OASANDONED OFLATTIRE OSINGLE UNEWINCHINO OMREST OSTOLENCM GOUT OF GAS GDUALUNEWINCHING OUNREGISTEREb OSREAK DOWN 'IMPOUNDED OSTgTCH BLOCKS OTOW mNE OLOCK OUT o - OSCOTCH BLOCKS OSNOWREMOVAL OSTMT D DDOILV TYFE OFIQW TWVED PER ORDER OF VEHICLETOWEDTO OSLINO/HOIST70W OSTATE POLICE FIRSTIOW ~ ~~qq S OFLAT SED OCAL POLICE E a~"' '~'WHEELUFT DOWNER SECONDTOW O ODEAIER STORAGE FROM TOWING CHARGE io DNYSFS MILEAGE CHARGE Paf ORP+ERS EXTRA PERSON OCHECK LIC NO SPECIAL E%P EOUIPM NT OCREDITCARD OMC OVL4A OAMEX DATE LABOR CHARGE ~~' ~ 1 3 rSTORAGE ©tG~ OPE R33IGNATURE DATE ~-Yp,P.A6~' Fn.Q tk- ~-t~~,~ a r~~ I% v A TR CK ~/ SUB-TOTAL I AUTHORIZED SIGNATURE DATE TAX VEHICLE RELEASEDTO DATE TOTAL ~ ~ ~ l.`y" Towing Service thank You IN THE COURT OF COMMON PLEAS LARRY E. JUMPER Plaintiff VERSUS TERESA D. JUMPER, Defendant No. DEGREE IN DIVORCE AND NOW, ~1 Jt ~^t ~~ Z~~, IT IS ORDERED AND DECREED THAT Larry E. Jumper PLAINTIFF, AND Teresa D. Jumper ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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; ~lN6f1PA4s+[a~o s..i ~aa., r.m 'e~ar..,n:~a.n= e, ems. ,, ~-., eww_-u a..wk;~F"i ~ i~SV€a- ,•~"`°" W~ '1 ~~ ~~~ LARRY E. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW N0.2001-5462 TERESA D. JUMPER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly 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 Complaint: A Complaint in Divorce was filed on September 19, 2001, and served on Defendant via constable on November 5, 2001. An Affidavit of Service was filed on December 6, 2001. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code: Plaintiff: July 3, 2003, filed July 11, 2003 Defendant: April 17, 2003, filed Apri121, 2003 (b)(1) Date of execution of Plaintiff's Affidavit required by Secfion 3301(d) of the Divorce Code: NA (2) Date of filing and service of the P1ain6fP s Affidavit upon the respondent: Filing: NA Service: NA 284579-I 4. Complete the appropriate paragraphs: (a) Related claims pending: None (b) Claims withdrawn: None (c) Claims settled by agreement of the parties: All (d) State whether any written agreement is to be incorporated into the Divorce Decree: Yes. Attached to Decree in Divorce. 5. (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached, if the Decree is to be entered under Section 3301(d)(1)(i) of the Divorce Code: Service: NA (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: July 11, 2003 Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Apri121, 2003 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: :~~ 284579-1 ~ I LARRY E. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW N0.2001-5462 TERESA D. JUMPER, Defendant IN DIVORCE CERTI\FICATE OF SERVICE AND NOW, this ~ day of 10\ , 2003, I, Andrew C. Spears, Esquire, of Metzger, Wickersham, Knauss & Erb, P.C_., att-o-rneys for Plainfiff, Larry E. Jumper, hereby certify that I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Karl R. Rominger, Esquire Rominger & Bayley 155 South Hanover Street Carlisle, PA 17013 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: Andrew C. Spears 284579-! C3 ,~ nns~ i [ °° G.'_ ems; -<•` ~ C; ~_, _ v r'. ` y~ ~ l.:> -< ~O ®/ 1 ~+ ,,~~ LARRY E. JUMPER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. TERESA D. JUMPER, Defendant N0.2001-5462 IN DIVORCE MARITAL SETTLEMENT AGREEMENT AGREEMENT, made this ~ day of V1 , 2003, between Teresa D. Jumper (hereinafter called "Wife") and Larry E. Jumper (hereinafter called "Husband") WITNESSETH: Diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto desire to settle fully and finally their respective financial and property rights and obligations as between each other, including without limitation: (1) the settling of all matters between them relating to the ownership of real and personal properly; (2) the settling of all matters between them relating to the past, present and future support and/or maintenance of Wife by Husband and of Husband by Wife; (3); and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. AGREEMENT NOT PREDICATED UPON DIVORCE It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for the institution, prosecution, defense or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds, nor to prevent either party from defending any such action which may, has been, or shall be instituted by the other party, or from making any just or proper defense thereto. The parties further agree that they will each sign the Affidavit of Consent and Waiver of Notice after the required ninety (90) day time period has elapsed when such a divorce procedure is instituted. 2. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Karl E. Rominger, Esquire, for Wife, and Andrew J. Spears, Esquire, for Husband. Each party acknowledges that she or he has received independent legal advice from counsel of her or his selection and that each fully understands the facts and has been fully informed as to her or his legal rights and obligations and each party acknowledges and accepts that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 2 n 3. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if she or he were unmarried. Each may reside at such place or places as she or he may select. Each may, for her or his separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to her or him may seem advisable. This provision shall not be taken, however, to be an admission on the part of either Wife or Husband of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with her or him. 4. PERSONAL PROPERTY Wife and Husband do hereby acknowledge they have heretofore divided the marital property, including, but without limitation, jewelry, clothes, furniture and other personalty, and hereafter, Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and, Husband agrees that all property in the possession of Wife shall be the sole and separate property of Wife. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, she or he may have with respect to any of the above items which are the sole and separate property of the other. Husband agrees to transfer to Wife upon execution of this Agreement, without further consideration and free and clear of all liens and encumbrances: 1. Husband shall transfer to Wife the Neon automobile free and clear of all liens and encumbrances. 2. Husband shall pay alimony in the amount of $3,000.00, said amounts to be paid in installments of $250.00 per month. 5. TAX RETURNS Husband and Wife agree to file separate returns from hereinafter. Husband shall pay all amounts do and owing form any and all past marital returns. Further, Husband shall indemnify wife against any penalty or interest for any tax due and owing as of the signing of this agreement. Husband further agrees that he will be responsible and hold Wife harmless for any contingent liabilities on joint income tax returns previously filed by the parties and will agree to pay any claim or expenses arising out of such returns or liabilities. 6. MEDICAL INSURANCE Husband agrees to a~ G,;s4/,•sS W ~ fe ~.q~ees C~~ss -~~ ~ /Y~P/!7: If f4~y 4~~ n~ CovQ~~f/ ~ vl~~~ wi~~ rlGy ~C/(~ 4 iYo~z t o/~C. 7. LIABILITIES Wife and Husband each covenant, warrant and represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other prior to or after the effective date of this Agreement, except as may be otherwise provided by the teens of this Agreement. 4 8. NO BAR TO FURTHER PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available. It is agreed that this Agreement shall not be impaired by any divorce decree which maybe granted but shall continue in full force and effect notwithstanding the granting of any such decree. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. 9. MUTUAL RELEASE Wife and Husband each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other xights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or temtory of the United States, or (c) any other country, or any rights which Wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may azise under this Agreement or for the breach of any thereof. It is the intention of Wife and Husband to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein above. 10. OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith (and within at least thirty (30) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectually the terms of this Agreement. 11. SUCCESSORS' RIGHTS AND LIABILITIES This Agreement shall, except as otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or assigns. ,, 12. ENTIRE AGREEMENT Wife and Husband do hereby covenant and warrant that this Agreement contains all of the representations, promises and agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there are no claims, promises or representations not herein contained, either oral or written, which shall or may be charged or enforced or enforceable unless reduced to writing and signed by both of the parties hereto; and the waiver of any term, condition, clause or provision of this Agreement shall in no way be deemed to be considered a waiver of any other term, condition, clause or provision of this Agreement. 13. BINDING EFFECT OF AGREEMENT This Agreement shall remain in full force and effect unless and until terminated pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 14. SEVERABILITY If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law, or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 7 15. HEADINGS Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meanings, construction or effect. 16. EFFECTIVE DATE The effective date of this Agreement shall be the date upon which it is executed; however, the transfer of the property provided for herein shall only take place upon the entry of a final decree in divorce, unless otherwise indicated. The support provisions of this Agreement shall take effect as indicated. Notwithstanding the foregoing, if a final decree in divorce shall not have been obtained within four (4) months from the date of execution of this Agreement, this Agreement shall be null and void. 8 17. CONTROLLING LAW This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. This Agreement is executed in duplicate, and in counterparts, and Wife and Husband, as parties hereto, acknowledge the receipt of a duly executed cop ~ hereof. y~ Witness ~ eresa D. Jumper/Wi Witness Larry E. Jumper/Husband ~- sc ~P~/~.je. ~. _~ ._l er~sci ~._._ J ~m~e~-_._ ._ _.. ......_ __ N u mb~~- ' __ 3 ~-1 ~L..1_c~3~~_4~ __ . _ _ _ _ _- - ._ 1 _ _hGc.S ~ _ ~-- ~_~_..._m~_~L.e..~._r_c~ ~___~.hs.._._._~~~L~~s_a_r_~r,_t_. t~rt~T+c~,.~-~~~, _ g).~ Q~SI~-:~SOCi~~eS _ _. _ _ _ __. v ~ .y-_m.~~t~ .h._y....1 ~s.urea.u~ce _. _ _ _ .. _ ____ __ _ ~1~, ~-_._----- _-_ _ . ._ _ _-- _ _- _ _ _ 5~ i v)~~~xr US. ~-ura?- 3~~103~1 ~ ~ fir. J~ktgen q T3r~o~{ wnvcl ~ very u~, ~arl~ S le ~~ ~~ a~ n~a 13calanc e : 3U , Cyr r~ ._ _~~~An~~4..~s' ~4 ~lJ~a ~~ - - - ~~ ~0 ~ I ~r~ l~ y Z ~ U c~a. 1~~ 15(~ ~• ~S' D~ ~ ~'G1,t~C'~ i ono <:ri>7$F l.nuc rkun r>k~°s ;~c,ur,lci~~r srfsu 110'7 M{>f1R~"rcTR R't? t..17~5t/Tt.k-ks Tn 11E7~&7 n~;z7~css s~ni~TC~ r~:1ok~sr~~r C'7i7J 784-4'e2B 47.115/q3 of i>fcG PFtonit rJ!.lPnrxEFi c;I..r~slrLra nArF TERESA Jitt4PER P.4. B4X 1496 CARE1:aL[, PA I7gI~-bg4b lun~I~uek~~nnu~gn~ku~B¢ul~ru~r~nr~~ro~eBurklnn~r~~ hdl~TE: Charges anti pnynlarrcs not aPp~arfny on ttds vli5b Nroiti9TTe iilegq~ym~~3 uu~~Y,SAA ^kp BiI1iNg irasietir'x7P~~l1~IVB~AY a 717-~s4-4sza 'From 8 AM to 5 PM WrISA/MASTERCARD AC:CEPTF-_D I___ CMECK 9dERE Por Creeiit f;4rd Payment Sh30VJ Af~dUUWT tL' PAID }-t F.: FiE ~P 2ri3'786 91 18.9G vv:;uri ,aa:~aunrr NclonaeR PAGE Na. raEdv 6nc.ArJ:.r LAPdC MMA Pt1YS MGMT/CEMT PEN 1194 M4UN'F4R RD L4YsUAt.LE, PA 17847-4299 ~nl~~Bmk~~w ekn~~ur~{r0u u~r ~~~ua~~ru#~rru lu ~r~~n{ r1;;lerneenl: will elf;hea! or, next nv>nth;.: `ulaLrtnerd• I''LE6,SE f4ETURN Th°l:i PGF-Il"IUPJ 4,NP"('F: PAYMEiP,fT CfiF.kGES ,c•.F`F'F=AfilhJi:1 C:N'FFdIS S"rATE'MEN7 AHE. NOT 3NC1-l.lDC.D fJN ANY h1L~SF'I-fAL.. E31 L.1-, (::Pi S'fATF..fvlf_'NT .o • -e • ~ +, r> v e 062402 NAVARRO M17 99222 IN~-PAT'SEN~f",Ihfi t"A'.AL>Lf:V 2 625.9 JUMPERS T .` 174.00 090fs02 NAVpRRO hiFD iBkUE $MIELiD PAYMEN'C _ -.--106.00 Q90642 MAVARRO hN ~BL:UE StdSCLO AUJUSThiLN'f -~-54.00 OSZ54Z-NAVARR$ MU ~-99232'~IN~-PAT-IBNT <.a1DFtSE4 LEV 2 625.9 SUMPERe T -i 83,@a - 49tlb42~-NAVARRO MU SLUE -ShcIELO PAYMENT 3(., ~ - -.5~i. a0 49tlb42 NAVARR$ cdiD $LUE ~FlIELD AIDJUSTMENT (/~ - - °23. am Lti~ P! m1/1~r 0.. F`LfA EIP. VB. A1'E (C4Ft dCi CI NT WI. dHEF' l:FfC~II I(JCd D61F'ti.iFf14G Nli G iF- r 1 > ~• ' 2437$6 car--.__~m=ma-IDar:-bm~~a--tpav"• ~ur~~ -._._,-aa Iaa~.~ '.`fasbt-.~_... ta~'-p~rxa~r~; rrrw~AiAn~f - G, I6.am ; s6.am a.am 16.ao JU iP ff]U~EREEk''CC7. - - - - -. -- - LAMC FI A PHYS Mtihid'.rCENC PEN _ f.71:' 1 T84,k328 1Xm4 MOUNTOR RID - - - - - ~l¢asa .make Paymarid: by return 10~`.^rVYLLF: f?A 170~oT ~ ~ - ma i.1-ar cexed:aak twr o'ffic<r .SRS is 233a1„'.255 lmmc~cdia4rxly+ 'tcr make paymm'L al°rangr.~nts. > .a¢ x10"" ..:e_.,~ _..._..,. s _ I ~Y'u.Rai.. 'uluTe~W4e.~61Y`~CY~~A9.-rvY rlrbr.M1i _ ~ . vccs~. CREDIT CARD PAYMENT You may pay this bill by credit card. Complete the form below and return in the enclosed envelope. AMOUNT: $ CREDIT CARU: CARD NUMBER: CARD EXPIRES: ~ MO. YR. PRINT CARD HOLDER'S NAME: SIGNATURE: Federal law requires that we advise you that the purpose of this communication is to collect a debt, and that any information obtained will be used for that purpose. 'r ,~ C".oatstrlir)ateci Cciltrt~~:tia~al 4cr~~icf~, Canc. ~ ~' t 7 ~~,S2-R6(11~ ~~g,(~Osl~ f„, k',q k7tt)fi ~ '~ > ~ ' > ~ :~r.~~~ , ~ S'I'A'~~L~~%IL< N1' ilEtT4'NI?Z^I7 &fib'L (46 )# PF 9;~SA F~ 7Y;h3Pk k: i4M E-r Fi.NPt 5'P w 2 C.'ARY.,ISI,]S I',A 1 C h+~16L,w@9@e+~~Q~U;~ F,'ofi21*If - .. .. 6fx2146 -.._.-. t) 2:1?•, .. - _1iVtC)Lt~vf'.INf [ [5y1 TD @o+~@~LLaB,oIIe~L,ll@,o+L6Ll„J( PCl 13ua 6214`,U - -- - ~ - - ^~ - rt - _~ ~'.~ x.~rF«r,«~ Y':i. I;'JC~f> (.onsoliea~ated (.ollee~e[~~1 Se-•ri~ca, Inc: (~o~~~ tint 7.)~~J =~=~-srC~~vn Rrc~trF~T-~~ Crcr,;itar Accauiafr # AmC C4cved T3LUE: M(?L'6T8°:f`AIN AMFaS'CkLE.SZA. N'a'9895 26.99 L7L°:I<~2. ';:E::'.E's7aA :D ~.F'iJ(~1r'ER Y'O'CJ' F7fa.Yti' k.'E•`.(.F,N'rC,%' a"~L)VE:aI::() .''l)_C)R. .."sC..+~trtv'I' S4AS YLrsCEY1 F~:)I2. ~:'C7L[.tli'"E'l:Gfrl-Y~):C'S'E~I ~C~C)1~ i3~'I?Trc, 'I'Ffi:a :i:. A '~R:iEiFJ':> i)LS,SI41- 4?tJIsT7C't SEr"P~IJS~ `tC'Ur1 ~V~. r2FiILF'I> 'I';~ I%iY TIT<S ~;:LTeIi~ C)R _.._ . C`CJNTAC''3' CAS: °:Et'raiiSE: `t0[.i I~Ei3~!E .IGiSt?R}I~Li C+C7FG Y'Ei.E!:~i'7:C)i7, fiaQ'I'7:'4:, ~ . GV'}: A'iTJtih'S' NP.i::f., E .,: u_7~<'t7Llt•1_%~P113 -t3Tv- a"f:1Cl- :4'( T'aY `1'!z't': AMi>L7NI '3F ,.~"tii~`~(' C"_TJ112i+I El`k' UNCLE 1>I;PL';`I' k~;~?1'.Mrs.L, T)T'C4iXaNC) 1,. F?7: ]~!~_ C°:Tif71: t)2: YC,C7 'FG Y''i^--~' S'Y-iii--AM{`.i~~YV'E' t)E? ,'"S(E:= C1v~CE~1 i""i`C f)NCIk' r I C F'[.rPA:ir; i)f'i NC)'i t~~i.l~. T ^i 27~+,. „~ :g'il't` Tf:, (:.'JN t AC"'[' `x'CiLf ~"-.C,i>_Eti ! ! ! ! *,tx,rxh***~rY%~"\Y THI;: Ar~)y.1*'"*******~R[JTEC'T' `iUUR CRE£iTT~**~*** CF.LI, 717~-65f:-86()7. 7P Yc'?Y; IEtALt. ANx' t~i.S.ESI fCahS~. TIII:S SS ,A"d s7 ZIJ9F':C I~U i:C)(,r Esf"T L ..,F'I I:r.Y YCJ?'C>RMFs`L'1C}k3 CJI'CASNLL) YdZLI,.fi.~.' T,7S'E;C, F'CTt °S'I-i=."I' FLYR~'C7SL AS AN ADDITIONAL CONVENIENCE, THIS OFFICE ACCEPTS VISA AND MASTERCARD. IF YOU WISH TO USE YOUR VISA OR MASTERCARD, PLEASE COMPLETE THE INFORMATION BELOW AND RETURN TO OUR OFFICE, f AUTHORIZE MY CREDITOR TO CHARGE MY OBLIGATION TO THE CHARGE CARD BELOW ^ VISA ^MASTERCARD ACCOUNT# CARD HOLDER NAME' :_ (Signature) EXPIRATION DATE _ AMOUNTS (Date) ~ .. ma.pggmkxNp?WR?N _ .. ... ..-..tER~l+~Y=.g-.sue' -..,::.-., fl ='.~.~:~i?-^t ia!~usi~ro ~"Yix%~4sasiil'Si Jon Barry ~ Associates, Inc. 216 LePhillip Ct ~ Concord NC 28025-2954 (888) 466-9634 Date: March 14, 2003 Account#: 3339699 RE: Teresa D Jumper Creditors: Carlisle Regional Medical 30.57 Total: $30.57 AMERICAN COLLECTORS association member NOTIFICATION OF ASSIGNMENT Your account(s) has been placed with this office for collection. Please mail the balance owed, or contact our office. This account may be reported to all three credit reporting agencies after 45 days if payment in full is not received. 00 $25.00 Service charge on all returned checks 00 Please use return envelope for all correspondence Debt Collectors Since 1986 Please Call: (888) 466-9634. Control No.: 9232784 This is an attempt to collect a debt and any information obtained will be used for that purpose. Untess you notify this office within 30 days that you dispute the validity of this debt or any portion thereof, this office will assume this debt is valid. If you notify this office in writing within 30 days of this notice, this office will: obtain verification of the debt or obtain a copy of a judgment and mail you a copy of such judgment or verification. If you request this office in writing within 30 days after receiving this notice, this office will provide you with the name and address of the original creditor, if different from the current creditor. If you wish to pay by VISA or MasterCard, fill in the information below and return the entire letter to us. Account Number Payment Amount Expiration Date Cazd Holder Name Signature of Cazd Holder Date March 14, 2003 .. JON BARRY & ASSOCIATES INC PO Box 748 Concord NC 28026-0784 #BWNHRMD 250238 29717 #0314 0834 0029 7179# 3339699-26 lu~lllu~l~lnnu~~ullnl~u~lu i~~lu~l~uhluilluuhll Teresa D Jumper PO Box ] 096 Carlisle PA 17013-6096 luhlluhlluuilrl~llullmlu~llululuhlullulu~~lll Account #:3339699 Balance Due: $30.57 Wilson St. Internal Medicine 220 Wilson Street Carlisle, PA 17013 ADDRESS SERVICE REQUESTEp Statement date Chart Number Page 02/04/2003 JUMT~00 1 Make Checks Payable and Send To: Wilson St. Internal Medicine 220 Wilson Street Carlisle, PA 17013 TERESAJUMPER PO BOX 1096 CARLISLE, PA 17013 wsim Amount Enclosed $ Check # ** THIS BILL WAS PREPARED BYACCUMED BILLING. ** FOR ALL BILLING QUESTIONS PLEASE CALL 717-702-5500. ------------------------'-------------`------------------- Please cut on dotted line and return top Portion w ith-Payment ------------------------------------------------ Balance Forward From Previous Statement 0.00 Patient: TERESA JUMPER Case Descrip: $15 PTS RESPONSIBILITY Amount Paid by Amount Paid By Dates Procedure Procedure Description Charge Insurance Guarantor Adjustments Remainder 11!04!02 99213 EST PT LEVEL Ill OFFICE VISIT 54.00 -37.00 0.00 -2.00 15.00 Past Due Ptease Pay Immediately! ** Ail charges are billed to the appropriate insurance carrier before you are billed. This balance is now the patients responsibility. Payment is due within 20 days from the statement date. We Thank You for payingyouraccountpromptly) Wilson St.lnternalMedicine 11125/2002 Amount Due 15.00 d> "a`~121'4II\~€F6. Yttw.`]&ffiPe&3~&iSd:._@kX,~4, 1:[Y£?SC#Y~XC2A5`33F~.-:__'-.. Pinnacle Health Hospitals ~,- ~ .. P.O. BOX 2353 HARRISBURG, PA 17105 (717) 230.3717 Ror Account Information, Please Call (717) 230-3717 Date 12/16/02 12/16/02 12/16/02 12/16/02 12:16102 - .. 12/16/02 12/16/02 12/16/02 12116/02. 12/16/02 12/16/02 12/16/02 12/16/02 12/16/02 12/16/02 12/21/02 02/14/03 02/21/03 02/26/03 PREVIOUS BALANCE 1 EMER MED VISIT III P/F99283 1 EMER MED VISIT III P/F99283 1 EMER MED VISIT III P/F99283 1 EMER-MED VISIT III P/F99283 -- - - Y E74ER' M~'II-VISIT iIi-P/F99283 1 EMER MED VISIT III 1 EMER MED VISIT III 1 EMER MED VISIT III 1 EMER MED VISIT III 1 EMER MED VISIT III ~ 1 VISIT .LEVEL 1 E 99281 1 PROMETH 25MG AMP J255D 1 PROMETH 25MG AMP J2550 2 MS 2MG SYR J2270 2 MS 2MG SYR J2270 BLUE CROSS DISCOUNT BLUE CROSS DISCOUNT B55 BLUE CROSS 36 BLUE CROSS DISCOUNT B55 BLUE CROSS 36 PMT-CBC 65 SPEC B55 BLUE CROSS 36 133 133 133 133 133 88 7 7 14 14 112 112 112 97 .DD .00 .00 .00- .00- :00 .D0 .00 .DO .00 .00 .00 .30 .30- .00 .00- .71- .71- .71 .46- )stimateddnsurance Due: .00 Total Patient Credits: Account Balance: 10.83 YOUR ACCOUNT IS PAST DUE! PLEASE CALL OR PAY IMMEDIATELY. CUSTOMER SERVICE HOURS MON-WED-FRI 7:OOAM TO 4:OOPM TUES-THUR 7:OOAM TO 6:OOPM CALL 717-230-3717 LOCAL OR 1-800-603-6064 OUT OF AREA PINNACE); HEALTH HOSPITALS P.O. BOX 2353 HARRISBURG, PA 17105 ADDRESS SERVICE REQUESTED ~r a ~~~u s~~~rw u~~u ~~u ~~u ~~u ~~~~w~~u~s~us~~m r~s~~ 00005763 1 AT 0.292 O1 223446888 THERESA D JUMPER PO BOX 1096 CARLISLE PA 17013-6096 ADM DT: 121602 DSH DT: `NONE` HOSP SVC: HER DX CD: 789.09 JUMPER ,TERESA 04110/03 Visa ~ Master®rd ~ Discover ~ Ameriren Express Make Check Payable To PINNACLE HEALTH HOSPITALS PINNACLE .HEALTH HOSPITALS P:O. BOX 2353 HARRISBURG, PA 17105-2353 Please check this box if your address or insurance information has changed and record the changes on the back of this statement Please use this space to make corrections to your address or insurance information Business Phone: Employer ' Employer Address Insnrance Company: -Effective Date:_ InsuranceCotnpanyAddress: Phone:- Insurance Polity or Conmact No: Group no•' _..._ , Polity Holder's Name: Phone:- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this, the ~ day of ,~Q,Q/"/ G , 2003, before me, the subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of Cumberland, personally appeazed ~F.iyfSF1 1~ . IUYnOf,~td in due form of law ,-- acknowledged the above Agreement to be her act and deed and desired the same to be recorded as such. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND nord,i~E ~]t?2i liada J. Jwn~sr, tvoiuy Public Cer~sle8oro, Cumberland County My CormrM&siott Expires July 23.2006 lckrnber i~emsylyrda 1ffiscaadon OI MotaAes SS. On this, the T7 '-{ day of ~,o,¢ i ~ , 2003, before me, the subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of Cumberland, personally appeared ~2er F ~%,„ ~~,~ and in due form of law acknowledged the above Agreement to be his act and deed and desired the same to be recorded as such. ~~~~~ NOTARIAL SEAL CAROL A. LYTER, NotarX Fubiic City of Harrisburg, f)guphin Oounty My Commission Ekes Dec. 28; 2U04 10 ,~.__ .. ~~, LARRY E. JUMPER, JR, Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: OI - S"SICa.. ~v~~~~ CIVIL ACTION - IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Teresa D. Jumper 102 Longview Drive Shippensburg, PA 17257 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. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Cazlisle, Pennsylvania 17013. 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 Court Administrator 4th Fl., Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Document #: 2]5377.1 Y LARRY E. JUMPER, JR, Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: ~ l -S~'tlG~~tc.~~~~ CIVIL ACTION- IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301 (d) OF THE DIVORCE CODE COUNT I -DIVORCE 1. Plaintiff is Larry E. Jumper, who currently resides at 102 Longview Drive, Shippensburg, Cumberland County, Pennsylvania 17257. Plaintiff's social security number 162-66-2345. 2. Defendant is Teresa D. Jumper, who currently resides at 102 Longivew Drive, Shippensburg, Cumberland County, Pennsylvania 17257. Defendant's social security number is183-60-8413. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 25, 1999, in Cumberland County, Pennsylvania. The parties sepazated on August 9, 2001. 5. 'There have been no prior actions of Divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. Document N: 275377.7 x 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff, Larry E. Jumper, Jr., requests the Court to enter a Decree in Divorce and such other orders as may be just and appropriate. Dated: ~6~~~ METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: Steven C ey, Esgw Attorney I.D. No. 74669 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorney for Plaintiff Document#:2[5377.1 VERIFICATION I, Larry E. Jumper, Jr., do hereby verify that the facts set forth in the foregoing Complaint are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswornfalsificationto authorities. Date: 9- ~ o-o ~ arry E. Jumper Document #: 215377.1 ,^4..e4~..h§d.Yo--.., ..~ _-_ .. ,. ~._ ~,_~ _ -_. ,. -_ , _ _ _ a-a~ Rt.~Nlit~a~ 'akuci:..~4v~&4iYS~xaa&!~Mr;~SrX~~ -" ~ - ll# N~ 1 1 `\~ \~ c ~ ` C il ..t T7 [5.. , rt,. ; ~ T ~: U, _, ~~ ~. ~+ ~ M fr' C ~~ ( ` ~aI "S LARRY E. NMPER, JR., Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 01-5462 CIVIL ACTION- IN DIVORCE AFFIDAVIT OF SERVICE Commonwealth of Pennsylvania County of ss. AND NOW, TO WIT, this ~ day of ~ 2001, comes the undersigned who being duly sworn according to law, deposes and says that he personally served a true and correct copy of the above captioned Divorce Complaint on ~j day of .C}G , 2001 upon Teresa D. Jumper. Sworn and subscribed to before me this ~ day ll~.rt /'~~ S~ ~.~G- NOTARIAL3EAL M~helie L. Sollenberger, Notary Pubflc FayatteWile, hanklin County My Coremission EXpires Oct. 5, 2002 Dacun:enl #: 217794.1 of J , 2001. LARRY E. JUMPER, 1N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION -LAW N0.2001-5462 TERESA D. JUMPER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 19, 2001, and served upon Defendant on October 5, 2001. Affidavit of Service filed December 6, 2001. 2. The marriage of plaintff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Dated: Lang E. Jumper Document #: 266455.1 c_ s° c:: -„ ~ -~ ~. , _ -_ f'sl E:: =~'. cn:;: _' : r ~ ~ ~' ~~~ "~, r : -,;- ._i ;n -~ cs~ .Cl~' LARRY E. JUMPER, 1N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW N0.2001-5462 TERESA D. JUMPER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER & 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer s fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Dated: 2@ nJ Lang E. Jumper Document#:266456.1 ca ~ a G: C3 -n 4. t~ ~~ ~s ~.i, n; _. ~ -," = - - - : _~ ~r: -' - -n -C~ ~ s~ c~ - -' c. ., ;n - .:_ _ rr ma ==C ire - c a~ LARRY E. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. TERESA D. JUMPER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 19, 2001, and served upon Defendant on October 5, 2001. Affidavit of Service filed December 6, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. T consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and conect. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Dated: ~J `1- 0 3 CIVIL ACTION -LAW N0.2001-5462 ~ ~ f ~/.~ ~'l /YYl ~~n ~ Teresa D. Jumper Document #: 266455.7 ~?~~\ ~~ LARRY E. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. TERESA D..IUMPER, Defendant CIVIL ACTION -LAW N0.2001-5462 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER & 3301(c) OF THE DIVORCE CODE I . I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit aze true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Dated: ~- ~~-~ ~~ ~~ ~ ~~~ ~eresa D. Jumper Document #: 266456.1 ,-, ~, ~..~ =- _., ~;. f7 fir,; _ i4} '.Y -r ~, ( ~. `; - _ .. r- ~~ 'L l ~~ LARRY E. JUMPER, JR., Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW TERESA D. JUMPER, N0. 2001-5462 CIVIL DIVISION Defendant IN DIVORCE PETITION FOR THE EQUITABLE DIVISION OF MARITAL PROPERTY, AWARD OF ALIMONY AND ATTORNEY'S FEES SUBSEQUENT TO THE DIVORCE ACTION 1. Petitioner is Teresa D. Jumper, the Defendant in the above-captioned divorce action. 2. Respondent is Larry E. Jumper, Jr., the Plaintiff in the above-captioned divorce action. 3. Respondent filed the divorce action on or about September 19, 2001. 4. The Petitioner intends to have this divorce matter referred to the Cumberland County Divorce Master for disposition. 5. Petitioner requests that claims for equitable division of marital property, permanent alimony and attorney's fees be considered by the court in conjunction with the granting of the divorce action. WHEREFORE, Petitioner respectfully requests that claims in reference to equitable division of marital property, alimony and attorney's fees be considered in conjunction with the granting of divorce in this action. ......, Respectfully submitted, O'BRIEN, BARK & SCHERER By: ~ ` Robert L. O'Brien, Esquire Attorney for Petitioner I.D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 rlo.diddomesticJjumper2.pet it ,, VERIFICATION I verify that the statements made in the foregoing Petition for the Equitable Division of Marital Property, Award of Alimony and Attorney's Fees Subsequent to the Divorce Action are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. !~• Teresa D. Jumpe Date: /D-o25-OI .~_ . ~ ~-~ ~~ - z ~~ ~ r., G"l . fJ - . ,: C; -_ ' = y ~~: _ _ ., i Z ~} , ~ _. _ '~ .~ C LARRY E. JUMPER, JR., Plaintiff vs. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 2001-5462 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE ORDER OF COURT AND NOW, this day of ~ c , 2001, upon review of the Petition for Special Relief, this Honorable Court orders and directs that the Respondent, Larry E. Jumper, Jr., appear before the Court on , the ~,0~ day of ~07 ~.n/~-.. , 2001 at -0V /p. m. in Courtroom No. ~, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. It is also hereby ordered that the Respondent not sell, transfer or otherwise dispose of the Dodge Neon, as well as the funds in the joint bank account pending said hearing. Robert L. O'Brien, Esquire Attorney for Petitioner/Defendant Co~~ n~ r Steven C. Courtney, Esquire 1 / Attorney for RespondentlPlaintiff ~~~ ~' Q~ 'e 1 lo~~~r'f BY THE COURT, ~~ lflNb'h"6',S~'vpd~~q ,~ ;_~ a.~l.l__.. _. ~,~. LARRY E. JUMPER, JR., Plaintiff vs. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-5462 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE PETITION FOR SPECIAL RELIEF 1. Petitioner is Teresa D. Jumper, the Defendant in the above-captioned action. 2. Respondent is Larry E. Jumper, Jr., the Plaintiff in the above-captioned action who currently resides at 102 Longview Drive, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Petitioner believes that the Respondent is disposing of marital property and notably is concerned about $8,000.00 that was in a joint bank account when the parties separated, as well as a recent model Plymouth Neon automobile which was purchased as a gift for the Petitioner. Attached hereto is an advertisement that Respondent placed in the Sentinel on October 24,2001. 4. The Petitioner respectfully requests that this honorable Court set a hearing on this special relief petition in order to enter an appropriate order or orders in reference to the disposition of the funds in the joint bank account, as well as the Plymouth Neon. 5. The Petitioner also requests that pending said hearing for special relief that this Honorable Court enter an interim order ordering and directing that the Respondent not sell, transfer or otherwise dispose of the Plymouth Neon, as well as the funds in the joint bank account. WHEREFORE, the Petitioner respectfully requests that the Respondent appear at a special relief hearing in order to address the issues of the disposition of the aforementioned items of marital property. Respectfully submitted, O'BRIEN, BARK & SCHERER By: ~~~_ Robert L. O'Brien, Esquire Attorney for Petitioner/Defendant I.D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717)249-6873 rlo.dirldomestic/jumper. pet VERIFICATION I verify that the statements made in the foregoing Petition For Special Relief are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. C>~~~ ~/ ~~~7~~~~ Teresa D. mper Date: ~®'~~~'~ :12-The Sentinel, Carlisle, Pa., Wednesday, October 24, 200] -825-, -:850_.. •8 Parts/ , Motorcycles/ TrU Accessories ; 7~a~ap~TVs ~ t :~ Y_ - Motors TransmLsswns YAMANA~1993 Virago, ~~ Rears Ins ied Wnh 17 00 Less than 6 000 cai mi Garage kept with uarantee 3year700000 cover fyleny extras: u New-Rel~ifl or~lsed ~ Great,Crytsm96lke iri DODGE;.B -ree Towmpa. Ed Auto ~> , -exgelfen~contlilion. In•. 4x4, Ve: Ai Rand. v~i_ p t v a upplme pf ~ _;° x "~~ ;1 288•'~7223'avenings ~ wN RV/~: ~~@I en Tr~i~era ~~ pc~`t w :Kehicles . IeP ca CAMPING MEMBERSHIP lifetime .Camp Coasl to ~ t anz ,r..„~,~~ py~a ._.. ._. . ..-,880 - Automobiles ;,For Sale ~ pLYNtbOTH 2000 Neon ~uloinehC eu CD Pow er ¢TaepPngrbrakes Ask- ~~In~aye0messege ino r~s~r~°:NArsn::_ ~~~~yyyyGG OHTJAC 1986 Grand AM, Ins~~pp~cted 702. eok f A la r$650 or best - 880 -. - Automoblles SUBARU 7987 Station Wagon 4 wheel dr. New . 'inspection 811res, '. .$1,000 486 4017. TOYOTA, 1998 Camry SE. 16k mi Gold. Load ., 'ed. Uke ndtV"Mu'st seal tyead78kmiwarranty , '.572,700 KsII4r"s,~laad u ~Cera 49~ 2~Y4~7~' offer. Ca11243-2659 or yULKSWA73EN,' aao-os27 ; , dens GLM. 5 syebd, PONTIAC, 1994 Sunbird head oil pump, all ' LE. 3.1 Liter, 5 speed. tor, front etrutes, I Anti-lock brakes, power CO playeC Sun r ~ RESIDENTIAL LISTINGS ~ ~ 101~ES-JUMPER 143 Allen 621 Martin Dr Frvw ............... ..............766-608J JORDAN E H Jr 5613 Pinhrst Way Mb Green Acres Mbrq .............................. .........:....697-7386 Jean G 102 Novmbr Dr Gphl....._......... 6 E Lisburn Rd Mbrg .......................... ..............766.6969 Jean L 218 N Pitt St Crls..................... elen Av Mbrg ...................................... ..............766.9386 Jahn 51808 Signal Hill Dr Mbrg...._.. R Fredrek Hsvr ......................._.......... ..............939.9438 Jos 15] Adams 51tn.................._.......... 5 Mounm View Rd Hmda ................... ..............732-1561 JuStln 17 E King St Ship...............;..... 13 Sholly Dr Mbrg .............................. ..............697-7006 K L 5613 Pinhrst Way Mbrg................. Oak Ln Ncum ..................................... ..............770-1210 Krist¢n 2409 Warren Way Mbrg........, 5 Cushing Greene CPhI ........................ ..............761-2575 L 380 S 2 Hrbg...................................... Skyline Rd Frvw ................................. ..............770-0785 Mabel 220 N Pitt St Crls..................... 4 Shiremonl Dr Mbrg .......................... ...............732-0780 Mark 2618 N Rosegarden Blvd Upal.... 47 Baltimore Pke Gdnr ....................... ............_486-0348 Mark 3 Sna Ln Mbrg............................ 51 Lee Ann Ct EPnb ............................ ..............728-3017 Mary E Mrs 300 S 4 Slm................... 7 Tunbridge Ln Crls ............................. ..............243-7712 Rithd E 3620 Logan Ct Cphl............... 1747 Pine Rd Nwvl ........................... ...............486-7799 Rithd E II4 Foxtail Ct Mbrg............. 619 Goodhope Rd Mbrg ...................... ..............975-2799 Rithd E III 210 Fox Dr Hmdn........... Barbara Ncum .................................. ...............774-0952 RoY M 300 S 4 Sltn............................. Pitt St Crls .................._.................... ...............241-9743 Russell E 2610 Shingus Cir Grhm....... n9ln Dr Mdtn ....................................... ...............939-8298 Rusty 5328 Oxford Cir Mbrg............... orting HIII Rtl Mhrg ............................. ...............761-8563 SCptS & Melissa 171 E Old Vork Rd immon Dr BISP ..................................... ...............258-3746 W M 2240 Canlrbry Dr Mbrg............... smn[ Av Ncum........._ .......................... ...............774.8979 WiIRe & Wanda 556 Butler Rd Crlb. rwood er Crls ................................. ...................243-8149 JORDANOFF Elizabeth Mrs 520 N Front Mountain Rd DIb9-~~~~~~~~~~~---~~~--- ~~--~-~~-~~-~.432-1426 JORICH Oanl3eo S 7 slm ................_.......... Pomfret St Cris._......._ .................... ...................243.5462 Donald W 414 Spruce Sltn.........._.............. altimore Rd OIb9 ............................. ...................432-09I5 Mary E 414 SPruce Sltn............................... 02 Hastings Dr UPaI ........................ ...................691-7073 TimOihY 807 Mohn SIN............................... 419 Range End Rtl Dlbq .................. ...................432.2382 JORRTYSMA Kenneth lz9 Peach Ln Crls.. treason Rd Crl rs 216 Elm Sltn 1023 Dogwd Ln 34 5 3 Sltn...... 5 Front Sltn..... J Mithael ll W Mapiwd Av Mbrg.... John 2018 Markel St Extension Mdtr John A alb Rupp Av Mbrg ................ Mark $teVen 308 Summit Ridge Dr P V 431 Meadow Dr Cphl ................... Rohs L 101 W Green Shtn ................. Cynthia 1040 Old Mountain Rd ranklintown Rd Dlhg........__......... 80 Highlnd Dr Mbrg ..................... 597 McClays Mill Rd Nwbg......... 201 Tory Cir Enoa ........................ Whetfld Dr Mdsx ......................... 619 Goodhope Rd Mbrg .............. '. 5328 Oxford Cir Laln.. '~ Oxford Cir Laln........... la 425 E Spring Valley 180 Bard Dr Ship......... n L 222 Indian Crk Dr Dr Mbrg ...................... Ladd R 317 W Main h a Dr Mbrg ..................... 17 S Front Sltn......._.... 5 6 LmYn ...................... fella Wrb9 .................................................. ........975.9065 Sinisa 114-A 2 HsPr.......................... 12 Teakwood Ln EPnb........ ....................... ........728.3379 5ladana 114-A 2 Hspr...................... 62 Rimer Hwy Crls ..................................... ........293.1341 JOY James T 147 Gardner Or Ship..... 564 Ma9aro Rd Epnb .................................. ........732.3968 John R 1029 Oogwd Ln Enoa............ 2 Hastings Dr Upal .................................... ........691.7073 Leonard J A12 Olde Scotland Rtl 5 1321 Carlisle Springs Rd Crls.._ .................. ........258.1586 JOYCE A R ll28 Colmbs Av Laln......, athy 409 Springfield Rd Ship ................... ........776.4795 Ed & Robin 126 W Ridge Rd Dlbg.. Devnshre Sq Hmdn .................................... ........766.0677 Edw F 5 EElmwd Av Mbrg.............. 0 Stone Church Rd Crls .............................. ........243.0745 EdW F III 1024 Getysbrg Pke Mhrg. . Lucinda Ln Mbrg ........................................ ........766.9451 Geraldine L Ridglnd 81ud Mbrg....... 185 Lucinda Ln Mbrg............__ ................... ........766.1654 Kathy L3905 Ridglnd Blvd Hmdn.... 59 N Hanover St Crls .................................. ........243.2739 Kathy Lynn Ridglnd Blvd Mbrg...... 12989 Enola Rd Crls ................................... .........243-0356 K¢Yln R 540 Bamsmble Rd Crls....... 7a6 Baltimore Pke Gdnr ........................... .........486-0916 Kimberly 4054 Caissons Ct Hmdn... 23 Dogwd Ln Enoa ...................................... .........728.1678 LaWrente T 1660 Ho01tz Rd Enoa.. A 3502 Countryside Ln Cphl ....................... .........975-0932 Mitha¢I P 205 Hemlock Rd Ncum... S Sz28 Coblstne Dr Laln ............................. .........790-0360 Peter S 508 Colony Rd Cphl............. Shirley A 205 Greenbrier Ln Dlbg ........... ........432.7862 Raymond IQ 601 Riverstix Ln Epn Cumberland Hwy Plhl ................................. .........532-0426 Raymond L Jr Ridglnd Blvd Mbrg.. :328 Blacksmith Rtl Cphl ........................... .........761.1603 RiChd L 1052 Hemlock Ln Enoa...... 17 Old York Rd Ncum .................................. .........774.3992 ROht fi22fi Stephens Crsg Mhrg........ m Penn Dr Cphl ........................................... .........737.0919 DOYEN Jean Therese 1020 w Foxc s913 Market Hmdn ...................................... .........737.5327 JOYNER Erit loo N Washngtn Mbrg D 34 Spring Lane Rd Dlbg ........................... .........432.5971 Jennifer 100 N Washngtn Mbrg...... Jr 905 Petersburg Rd Cris ......................... .........243.2402 JOYNT Darlene M lOZS Market Lm t39 6 Av Swta ............................................. .........939.1213 JOZEFIAK J 143 Fieldstone Dr Mdsx t39 6 Av Swta ............................................. .........939.4047 JRSELNICK Gregory a91 N 25 Cp 'aul 1221 Kings Cir Hmdn ......................... .........732-1369 JUARE2 Alberto 5 Dogwood Dr Shil t 228 E Garfield St Ship ............................. .........530.1638 D¢Vid Sr 211 N Queen St Ship........ 98 Tart Cir Enoa ........................................ .........728.9924 Jaime 246 Walnut 5t Crls................ 823 Ridge Rd Ship ...................................... .........423.0016 JUBIC Ro6t J 309 Salt Rd Enoa...... 155 Pine Hiil Rd Enoa ................................ .........732.2684 JUBRAN Amal A 1048 Hemlock Ln 5012 Muirfld PI Mbrg ................................ .........730.6774 Mithael H 1048 Hemlock Ln Enoa. 11772 Weingm Dr Mdm ............................. .........939.8298 JUCHEM Ron 526 W Simpson Mbrg 76035 Bumt Mill Rd Nwbq ....................... .........423.6796 JUDD Deborah R 1418 Bradley Dr I t 3 Pocono Dr Mhry .................................... ..........697.6033 Harry E 3 Country CI46 PI Cphl...... C 166 Bentz MIII Rd Wivl ........................... ..........432.0724 JUDGE Jahn A 2007 Columbia Av t E Rev 2650 Spring Rtl Crls ....................... ..........243.9362 John A 2007 Columbia Av Cphl....... F Jr 1264 Mainsville Rd Ship ..................... .........532-6957 Mithael John 6105 Haymarket W Franklin 102 Middle Spring Rd Ship ........ ..........532-6077 Thos B 357 Martingale Dr Cphl....... M 909 W Old Vork Rd Crls ......................... ..........243-2196 Wm E 421 SpmghSe Rd Cphl.......... & Rosalind 4 Penza Ct Dlbg .................... ..........432-5656 JUOITZ Ro6t E 7708 Wyndham Rd z Meadow View Dr Dlbg .............................. ..........502-0892 JUDSON Ann Marie 5lz Bridgvwl 74 Junction Rd Dlbg ..................................... ..........432-2872 John Darid 504 Orr'S Bridge Rd C 13 Evegm Rd Fmv ..................................... ..........779-3773 John P 512 Bridgvw Dr LmYn......... S4 Magaro Rd Epnb ..................................... ..........732-3968 John P MD 512 Bridgvw Dr Lmyn. Ib Appalachian Av Mbq .............................. ..........795.9886 JUDY D¢Rpn 7 Shea Ct Crls..:......i_. 7 KenSggm Dr Cphl ...................................... ..........737.7978 Ge0 H Jr 104 Rpop Hspr................ Derorlna Crls ........................................... ..........240-1286 Jerry N 616 Brad St Ship............... thael 533 High SvRa ................................. ..........939-9569 Jos H 705 Shadr Ln Enoa............... J M 313 Eutaw Av Ncum .......................... ..........774-0497 L 224 Reno Av N<um........................ t 1409 W Loulher St Crls .......................... ..........243.3020 M A 4 Sportsman Rd Enoa......._..... I Lincoln Dphf ............................................... ..........761.3182 Melissa 1765 Roselle Av Lswla....... 170 Old State Rd Gdnr .................................. ..........486-0561 Mithael 1765 Roselle Av LsNa...... i3 Brandt Av Ncum ....................................... ..........774.1778 Patricia A 7 Shea Ct Crls.............. x.........732.4089 JUOY.R L 4 SPOYDmIdn Rd Enoa ........................................ ....791.9447 ' ..........972-8516 JUERGEN$ Brute E u2 Gettysburg Dlbg .................... ....432.4748 ...........249-7054 JUGAN Gary R 901 Kent Dr Mbrg ................................... ....732-5154 ..........732-2588 JUGOVIC Fddil 214 Hummel Av Lmyn ............................ ....731.1809 ...........939.6495 JUHASZ John C zoo Penn Hzpr ...................................... ....986.0629 ...........532-9899 JUHL Heinz G PhD 2 Drier Rd cpnl ............................... ....763-4738 ..........732.4089 JUKES Jeffrey Lg WiMrose Ln Mbrg ............................ ....766.4861 ...........761.4309 Melanie L g wildrose Ln Mbrg ...................................... ....766.4861 ...........986.0342 JUKES 5aml 1039 Pennslrvania Av Nrbq ......................... ....939.0175 ...........243.9053 JULIAN Anthony J 344 s 2 sfm .................................... ....939.9989 ...........697.5778 Anthony Jr 10311 Princess Dr Obld ................................ ....939-2631 ...........761.8337 Erik & Stephanie s3 aid cabin Hllw Rd Dlbg ............. ....432.7979 ...........939.9017 John F 35 Maybry Ln Mhr9~~~~~~~~~~~~~~ .............................. ....790-9318 ...........761.2951 Mithael A z3oa 5 4 Slm ............................................... ....939-1245 ...........732-0416 Raymond J 351 S from sltn ......................................... ....939.1755 ...........763.1542 JULIANA Anthony 374 Steigerwalt Hollow Rtl Ncum.... ....774-0977 ...........939.9017 Danl T 20 Kingswd Dr Mbrg ............................................ ....791.1230 ...........766.7941 L M & Mark 54 S Pin oak er 81sp ................................ ....241.2754 ...........766.0176 P A 36 W Coaver St R Mbrg ............................................ ....691-3607 ...........240-2667 P E 77 5 z wfvx .............................................................. ....732.2263 ,..........790-9094 Peter V 366 Steigerwalt Hollow Rd Ncum ...................... ....774-0664 .....:.....243.1267 Shari 20 Kin9swd Dr Mbro ................ 791-1230 1LIA5 Christopher T 611 Nlghland Av Oeano T 1009 Redwood Dr Crls ................ Harry T 129 Chester St Crls ..................... Steve Jr 13 Winchester Gardens Crls....... Timothy D 304 James Mbrg .................... Tam 227 N Bedford St Crls ....................... Wapde L 304 James Mhrg ....................... ILIU$ Christine 1015 Lisburn Rd Wlvl. Edwin A 3 Victra Way Cphl ..................... Emil F 208 Senate Av Cphl ....................... Margaret Mrs 3 Vidra way Cphl........... Andy 7500 Molly Pitcher Hwy 5 .Ann M 1136 Rockledge Or Crls. B K 18 Goodhart Rd Ship........... Barry C 30 Conrad Rd Crls......., B¢Yleh 6 Soum Rtl Mbrg........... Boyd L510 School Av Crls........ Bndl¢y'.R 255 5 Middlesex Rd Brenda C 115 E Main Mbrg..... Brenda L na w Loutner St Cd Bryon N 33 S High St Nwvl...... C William 458 W Main St Wlbt .................. 43 Water Sl Wlbt ........................ C¢IYin W 167 Frylown Rd Crls. Carl 81 N Hollar Dr Ship........... Carl E 1528 Terrace Av Crls..... Christopher A 389 Bobcat Rd Christopher L 1575 Webster I Chra E 16 Mt flock Rd Nvrvl.... Clarence 312 Ross Av N<um.... Cnrtls A 658 Hillcrest Dr Crls.. D 13713 Rasmn[ Av Cphl........... D M 13 N Queen St Ship............ Darrin G 350 Sawmill Rd Nwvl David A 1528 Terrace Av Cris.. DdVld G 40 Colonial Cl Ship..... David E 62 Cave Hill Dr Crls.... David E II 23 Park 5[ Mhsp.... David L 13215 Ncum ............... Dlann¢ M 39 N Baltimore Av f Donald F 12 Springfield Av Nw Donald R 137 N west st cris.. Donald S 254 Petersburg Rd C 15 8 Blaserviile Rtl Grls........... E 424 Factory St Crls....,, 880 Reservoir Dr Crls.......... 132 S Ridge Rd Blsp..........,, e N High St Nwvl ................. ' 3780 Spring Rd Crls........... E h 24 McAllister Chu¢h H 205 Mealz Dr Crls.......... W 801 Sandbank Rd Mhsp.. 7073 Carlisle Pke 7005 Salem Prk E 1041 May Appl JOeI D 19 Orange Sl MhSp.... K 312 N ll Cphl_...._....._..... Kendra C bsa H illcrest Or L J 248 E North St Crls......... Larry Jr 102 Longview Dr SI Leroy E 413 Mountain View Leslie H 25 Cobblestone Dr I Llsler E 5049 Orrstown Rd Lester E 5049 Orrstown Rd n ~_ Tail-' ~11 ~1~ .~j - Lt i...i - r 4~ l .f}r ~_ G'i~ "4! D( i..i l~ "~" ~ i +,} c:iJ t~i • , LARRY E. JCT1b1PER, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW TERESA D. JUMPER, Defendant NO.O1-5462 CIVIL TERM ORDER OF COURT AND NOW, this 6a` day of December, 2001, upon consideration of Defendant's Petition Requesting Counseling, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Steven C. Courtney, Esq. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Attorney for Plaintiff Robert L. O'Brien, Esq. 17 West South Street Carlisle, PA 17013 Attorney for Defendant is ,o~- ni ~' {, ~-_ > c _ ~' c:,:. __ _' c --„ , -- A~ TY -~<, w :rc LARRY E. JUMPER, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL DIVISION -LAW TERESA D. JUMPER, NO. 2001-5462 CIVIL DIVISION Defendant IN DIVORCE ORDER OF COURT r ~ +~ . - AND NOW, this day of , 2001, upon review of the attached petition, the Court orders and directs that the Plaintiff, Larry E. Jumper, Jr. and the Defendant, Teresa D. Jumper, attend three counseling sessions with Franco Associates, said sessions to be scheduled by the Defendant. BY THE COURT, J. Wesley Oler, Jr., J. Robert L. O'Brien, Esquire Attorney for Defendant/Petitioner Steven C. Courtney, Esquire Attorney for PlaintifflRespondent li ~t ~ . ~~ LARRY E. JUMPER, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL DIVISION -LAW TERESA D. JUMPER, N0.2001-5462 CIVIL DIVISION Defendant IN DIVORCE PETITION REQUESTING COUNSELING 1. Petitioner is Teresa D. Jumper, Defendant in the above-captioned divorce action by her attorney, Robert L. O'Brien, Esquire. 2. Respondent is Larry E. Jumper, Jr., Plaintiff in the above-captioned divorce action. 3. Petitioner requests that the Respondent be required to attend three counseling sessions with the Petitioner within the ninety days following the acceptance of the divorce. The Petitioner has determined that Franco Associates will provide counseling pursuant to the health insurance plan that presently covers both parties. 4. .Respondent does not concur with this request. WHEREFORE, the Petitioner respectfully requests that the Court order and direct the Respondent, Larry E. Jumper, Jr. to attend three counseling sessions with the Petitioner, Teresa D. Jumper. Respectfully submitted, O'BRIEN, BARK & SCHERER 1 Robert L. O'Brien, Esquire Attorney for I.D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 VERIFICATION I verify that the statements made in the foregoing Petition Requesting Counseling are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. a U! Teresa D. Jum er Date: -r~i CJ C_ ~a ---_ Ci ail[., :'? _ - :r CT.i ~, ' ..`. ,7 -~ K : _' , _ "' ;~ ~ ~ -'° T (V? s r:C (~ j -~{ K h,y { ~ N ~ •4 a LARRY E. JUMPER, JY2., Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 2001-5462 TERESA D. JUMPER, CIVIL ACTION - IN DIVORCE Defendant ANSWER TO DEFENDANT'S PETITION REQUESTING COUNSELING AND NOW, comes Plaintiff, by and through his attorney, Steven C. Courtney and Metzger, Wickersham, Knauss & Erb, P.C. and files the following Answer to Defendant's Petition Requesting Counseling: 1. Admitted. 2. Admitted. 3. Denied. While it is admitted that Petitioner is requesting that Respondent be required to attend three (3) counseling sessions, it is DENIED that it was not successful. Respondent feels that additional marriage counseling is not necessary and will not prove successful. 4. Admitted. WHEREFORE, Respondent hereby requests this Court deny Petitioners Request that he be required to attend three (3) counseling sessions with the Petition. METZGER, By: ~~~ ~G ~ Dated: Document #: 222776.7 ERB, P.C. ...,, .. A orney I.D. No. 74669 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff _.. .-_, xau.u_..isuuuaw.uesu ~ ~~a,~smys_ i ~ ~ `s ~ ~ , CERTIFICATE OF SERVICE AND NOW, this 13th day of December, 2001, I, Steven C. Courtney ,Esquire, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Respondent, Larry Jumper, hereby certify that I served a copy of the within Answer to Defendant's Request for Counseling this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Larry Jumper 102 Longview Drive Shippensburg, PA 17257 Robert O'Brien, Esquire 17 West South Street Carlisle, PA 17013 Attorney for Petition Document #: 222776.1 ia~arais'L'smas3~abiY~a%s.~~~:~t~5~~.s ~,~, ..., ~ - .:mss: ~s:6 .~;,mi _< „~a:z~'ti1w:a~ussac~.x~a~aii -s- ...w.~. : :,. <.~ .._ .. O F P e> c~ r: - c_ ~, -- -~ n~t:r, c'~ ~_• ~ _ =i~ ~' >^ _. 3 ~_J .. _I -"t _T a1 .e.. ..~ -r") W R/~~~ a LARRY E. JUMPER, JR., Plaintiff v. TERESA D. JUMPER, II Defendant AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW NO. 2001-5462 IN DIVORCE CIVIL DIVISION ORDER OF COURT day of January, 2002, upon review of the attached petition, the Court orders and directs that the Plaintiff, Larry E. Jumper, Jr., and the Defendant, Teresa D. Jumper, attend two counseling sessions with Franco Associates, said sessions to be scheduled by the Defendant. BY THE COURT, J. Wesley Oler, Jr., J. Robert L. O'Brien, Esquire Attorney for Defendant/Petitioner Steven C. Courtney, Esquire Attorney for Plaintiff/Respondent LARRY E. JUMPER, JR., Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW NO. 2001-5462 CIVIL DIVISION IN DIVORCE ORDER OF COURT ~ AND NOW, this day of January, 2002, upon review of the attached petition, the Court orders and directs that the Plaintiff, Larry E. Jumper, Jc, and the ~~ Defendant, Teresa D. Jumper, attend two counseling sessions with Franco Associates, jl said sessions to be scheduled by the Defendant. BY THE COURT, J. Wesley Oler, Jr., J. Robert L. O'Brien, Esquire Attorney for Defendant/Petitioner Steven C. Courtney, Esquire Attorney for Plaintiff/Respondent .« LARRY E. JUMPER, JR., Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW NO. 2001-5462 CIVIL DIVISION IN DIVORCE ORDER OF COURT ii AND NOW, this day of January, 2002, upon review of the attached i~ petition, the Court orders and directs that the Plaintiff, Larry E. Jumper, Jr., and the it Defendant, Teresa D. Jumper, attend two counseling sessions with Franco Associates, II said sessions to be scheduled by the Defendant. BY THE COURT, J. Wesley Oler, Jr., J. ~~, Robert L. O'Brien, Esquire ;j Attorney for Defendant/Petitioner ~~~ Steven C. Courtney, Esquire I~ Attorney for Plaintiff/Respondent ~, ~ LARRY E. JUMPER, JR., Plaintiff v. TERESA D. JUMPER, Defendant 1 action. 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW NO. 2001-5462 IN DIVORCE CIVIL DIVISION PETITION FOR COUNSELING Petitioner is Teresa D. Jumper, Defendant in the ~ :_~ r. -. r __ ~- CsJ ~ ~ ; r ~ di~rce= ~?, ~~ ~~~ .. __, ' 3 ~r -~. Respondent is Larry E. Jumper, Jr., Plaintiff in the above-captioned divorce action. 3. In early December, 2001, the Petitioner, Teresa D. Jumper, requested that the parties attend counseling sessions. 4. 23 PA C.S.A. Section 3302 requires that the Court shall direct counseling if requested by a party. The Petitioner requests that the parties attend two counseling sessions and that the Court issue the order attached hereto. i Respectfully submitted, O'BRIEN, BARIC & SCHERER Robert L. O'Brien, Esquire Attorney for Defendant I.D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717)249-6873 rlo.diddomesticljumper5.pet 14. i l LARRY E. JUMPER, JR., IN THE COURT OF COMMON PLEAS OF !~ Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA l li v. CIVIL DIVISION -LAW TERESA D. JUMPER, NO. 2001-5462 CIVIL DIVISION Defendant IN DIVORCE l ~~ ORDER OF COURT AND NOW, this day of January, 2002, upon review of the attached ~~ petition, the Court orders and directs that the Plaintiff, Larry E. Jumper, Jr., and the I~', Defendant, Teresa D. Jumper, attend two counseling sessions with Franco Associates, ii said sessions to be scheduled by the Defendant. BY THE COURT, Robert L. O'Brien, Esquire I Attorney for Defendant/Petitioner ~~, Steven C. Courtney, Esquire 'i Attorney for Plaintiff/Respondent ~i 'I ~' I J. Wesley Oler, Jr., J. l LARRY E. JUMPER, JR., Plaintiff v. TERESA D. JUMPER, ~~ Defendant s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW N0. 2001-5462 IN DIVORCE CIVIL DIVISION PETITION FOR COUNSELING 1. Petitioner is Teresa D. Jumper, Defendant in the action. c: Fti '~.9 1 r~ i:- ,,33 `(.. .. ,_, :.-` CSI -G 2, Respondent is Larry E. Jumper, Jr., Plaintiff in the above-captioned I divorce action. 3. In early December, 2001, the Petitioner, Teresa D. Jumper, requested i f that the parties attend counseling sessions. ~~ 4. 23 PA C.S.A. Section 3302 requires that the Court shall direct counseling if requested by a party. The Petitioner requests that the parties attend two counseling I sessions and that the Court issue the order attached hereto. Respectfully submitted, O'BRIEN, BARK & SCHERER Robert L. O'Brien, Esquire Attorney for Defendant I.D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 rl o. d i r/domestic/j u m p e r5. p et ~.~. LARRY E. JUMPER, JR., Plaintiff v. i TERESA D. JUMPER, Defendant ,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW NO. 2001-5462 CIVIL DIVISION IN DIVORCE ORDER OF COURT !~ AND NOW, this day of January, 2002, upon review of the attached j II petition, the Court orders and directs that the Plaintiff, Larry E. Jumper, Jr., and the 1i Defendant, Teresa D. Jumper, attend two counseling sessions with Franco Associates, ~~ said sessions to be scheduled by the Defendant. it '! BY THE COURT, it I! J. Wesley Oler, Jr., J. Robert L. O'Brien, Esquire Attorney for Defendant/Petitioner Steven C. Courtney, Esquire '„ Attorney for Plaintiff/Respondent ''. r LARRY E. JUMPER, JR., Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW NO. 2001-5462 IN DIVORCE PETITION FOR COUNSELING 1. Petitioner is Teresa D. Jumper, Defendant in th action. CIVIL DIVISION [ j C-J j il ,7 ~~ r ^ 7,' ! n ,. 07 , ,, ri_ c:- above-captd ~, =, dt~orce ~ c.a y 11 `-~ -~ =-a cs~ e =u =K: 2, Respondent is Larry E. Jumper, Jr., Plaintiff in the above-captioned ~ divorce action. 3. In early December, 2001, the Petitioner, Teresa D. Jumper, requested that the parties attend counseling sessions. 4. 23 PA C.S.A. Section 3302 requires that the Court shall direct counseling if requested by a party. The Petitioner requests that the parties attend two counseling sessions and that the Court issue the order attached hereto. Respectfully submitted, O'BRIEN, BARK & SCHERER Robert L. O'Brien, Esquire Attorney for Defendant I.D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 rlo.dir/domestic/jumper5.pet t LARRY E. Ji JMPER, JR., IN THE ~;OURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW TERESA D. JUMPER, Defendant NO.O1-5462 CIVIL TERM ORDER OF COURT AND NOW, this 22"d day of January, 2002, upon consideration of Defendant's Petition for Counseling in the above-captioned matter, and of the Plaintiff's Answer to Defendant's Petition Requesting Counseling, the parties are directed to attend two counseling sessions with Franco Associates within the next 45 days, the expense of which shall be borne by Defendant and the times of which shall be by mutual agreement. BY THE COURT, Steven C. Courtney, Esq. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Attorney for Plaintiff Robert L. O'Brien, Esq. 17 West South Street Carlisle, PA 17013 Attorney for Defendant esley Oler, r J. ' ''~~.~ ~ :rc a r.i 1m rv nlJ ~w.44~'~~:~. sM 5t '- -~PNWtt'"" -INE~k4'xx~+ur+bmeP " ~ .. ~ •. dl~'dA'1hSNN3d A{.~{f1G~t f1P~=;.~1~hi~{Ntl~ c~ ,~i ~~~ £~ ~~~E' ~0 [L, A~"f1.Gh i ~ ,~~ ,',~ i ~~ `~YJ _~ ~ ~ ~~1i ~ S o ~ .' ~ ~ LARRY E. JUMPER, JR., Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW NO. 2001-5462 CIVIL DIVISION IN DIVORCE ORDER OF COURT AND NOW, this day of January, 2002, upon review of the attached petition, the Court orders and directs that the Plaintiff, Larry E. Jumper, Jr., and the Defendant, Teresa D. Jumper, attend two counseling sessions with Franco Associates, said sessions to be scheduled by the Defendant. BY THE COURT, J. Wesley Oler, Jr., J. Robert L. O'Brien, Esquire Attorney for Defendant/petitioner Steven C. Courtney, Esquire Attorney for Plaintiff/Respondent LARRY E. JUMPER, JR., Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION -LAW NO. 2001-5462 CIVIL DIVISION IN DIVORCE PETITION FOR COUNSELING 1. Petitioner is Teresa D. Jumper, Defendant in the above-captioned divorce action. 2. Respondent is Larry E. Jumper, Jr., Plaintiff in the above-captioned divorce action. 3. In early December, 2001, the Petitioner, Teresa D. Jumper, requested that the parties attend counseling sessions. 4. 23 PA C.S.A. Section 3302 requires that the Court shall direct counseling if requested by a party. The Petitioner requests that the parties attend two counseling sessions and that the Court issue the order attached hereto. rlo.dir/domestic/jumpers. pet Respectfully submitted, O'BRIEN, BARK & SCHERER Robert L. O'Brien, Esquire Attorney for Defendant I.D. # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 tiN (I ~ P =' -~ ~ _ -- " z .~_ ; - ~,, _ -= ~: ti G-'1 " Ga =; i ~ ~ t ~ .. .~ SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY' S OFFICE DATE: July 15, 2003 DOCKET NUMBER: 2001-5462 PLAINTIFF/PETITIONER SS#: 162-66-2345 NAME: Larry E. Jumper, Jr. DEFENDANT/RESPONDENT SS#: 183-60-8413 NAME: Teresa D. Jumper 284591-1 .. v LARRY E. JUMPER, JR., Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.O1-5462 CIVIL TERM ORDER OF COURT AND NOW, this 15a' day of July, 2002, upon consideration of the Petition to Withdraw as Counsel, a Rule is hereby issued upon Plaintiff and Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Steven C. Courtney, Esq. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 Attorney for Plaintiff Robert O'Brien, Esq. 17 West South Street Carlisle, PA 17013 Attorney for Defendant Larry E. Jumper, Jr. 102 Longview Drive Shippensburg, PA 17257 Plaintiff :rc ~~ `" ilif ~~ ;~' ,, r ~; s~~ ~ ~ . . ~ . A LARRY Ee JUMPER, JR, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v NO: 01-5462 TERESA D. JUMPER, CIVIL ACTION - IN DIVORCE Defendant . RULE TO SHOW CAUSE TO: Larry E. Jumper, Jr. 102 Longview Drive Shippensburg, PA 17257 You are hereby directed to show cause, if any you have, why the relief requested in the foregoing Petition of Metzger, Wickersham, Knauss & Erb, P.C., to withdraw as your counsel should not be granted. Rule returnable within days of service. BY THE COURT: J. Document #: 231908.1 s ~ _. LARRY Ee JUMPER, JR., Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 01-5462 CIVIL ACTION - IN DIVORCE ~,;'~l~f-t'o,J TU ~CJ~'t"~CJ.2d` L~ ~S ~[.@.JS£ 1. On September 19, 2001, Steven C. Courtney and the law firm of Metzger, Wickersham, Knauss & Erb, P.C., filed a Complaint in Divorce on behalf of Plaintiff, Lany E. Jumper, Jr. in the above referenced matter. 2. The undersigned and Metzger, Wickersham, Knauss & Erb, P.C, seek leave of court to withdraw as counsel for, Plaintiff, Larty E. Jumper, Jr. for the following reasons: (a) Defendant has become uncooperative with counsel. (b) Defendant has significant outstanding amounts due to the undersigned which he is refusing to pay. WHEREFORE, the undersigned and Metzger, Wickersham, Knauss & Erb, P.C., respectfully request that a Rule be issued upon Plaintiff, Larry E. Jumper, Jr. to show cause, if any he has, why the within Petition for court approval for the undersigned to withdraw as his counsel should not be granted. METZGER, Attorney Id. 7669 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorneys for Plaintiff Dated: July ~, 2002 KNAUSS & ERB Document#:237867.1 CERTIFICATE OF SERVICE I, Steven C. Courtney, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and exact copy of Petition to Withdraw as Counsel with reference to the foregoing action by First Class Mail, postage prepaid, this day of July, 2002, on the following: Robert O'Brien 17 West South Street Carlisle, PA 17013 Attorney for Defendant Larry E. Jumper, Jr. 102 Longview Drive Shippensburg, PA 17257 Plaintiff KNAUSS & ERB Steven C. ey, E uire Attorney Id. 74 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorneys for Plaintiff Dated: July ~, 2002 Document #: 237~47D.1 ,- 'C1 ~ ~~TT1fTt . s C ~ -~ ~'n f L i -- :t'_ -7.:1 G ! ~?, r:., O ~ j .cwt.-y . C'l ~' r i°'J , = .. _ ~ t ^ti i: f ti _'i{' r 1' W I ^\ l 1~ LARRY E. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW TERESA D. JUMPER, Defendant NO.O1-5462 CIVIL TERM ORDER OF COURT AND NOW, this 18~' day of February, 2005, upon consideration of Plaintiff's Motion for Continuance, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 10 day of service. /Jennifer L. Spears, Esq. 10 East High Street Carlisle, PA 17013 Attorney for Plaintiff ~arl E. Rominger, Esq. 155 South Hanover Street Carlisle, PA 17013 Attorney for Defendant BY THE COURT, Q2-I $ -Q~ :rc - ~, S,~ ~ .. .~ FEB 1 7 2005 ~ i LARRY E. JLIMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Movant CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-5462 CIVIL ACTION -LAW TERESA D. JiJMPER, Defendant/Respondent IN DIVORCE ORDER AND NOW, this day of , 2005, upon consideration ofthe foregoing Motion for Continuance of Movant, and by agreement of the parties, the hearing previously scheduled for Thursday, March 31, 2005, is herebyrescheduled to , 2005, at m. in the Cumberland County Courthouse, Courtroom No. ,Carlisle, Pennsylvania. BY THE COURT, J. ~F:\FILES\DATAFILE\GevaaACurtrnt\113]1.16 motioacontmumce\tde ~ Revised: Yld/OS 9:18AM 10613.4 Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff LARRY E. JUMPER, Plaintiff/Movant v. TERESA D. JUMPER, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5462 CIVIL ACTION -LAW IN DIVORCE PLAINTIFF'S MOTION FOR CONTINUANCE AND NOW, comes the Movant, Larry E. Jumper, by and through his attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby moves the Court to continue the hearing on Defendant's Petition for Contempt currently scheduled for March 31, 2005, for the following reasons: 1. This hearing was scheduled at the request of Defendant on her Petition for Contempt. 2. A hearing on Defendant's Petition for Contempt is scheduled for March 31, 2005, at 2:30 p.m. 3. Movant is requesting that the hearing scheduled for March 31, 2005, be continued as he will be in Haiti doing mission work with his church. All paperwork has been completed and his tickets are prepaid. 4. Movant will be returning to Pennsylvania on or about Apri14, 2005. 5. Counsel for Respondent, Karl E. Rominger, Esquire, has been notified of this request for a continuance, but does not concur. 6. No prior continuances have been requested in this matter. WHEREFORE, Movant, Larry E. Jumper, requests Your Honorable Court to reschedule the hearing from Thursday, March 31, 2005, to a mutually convenient time for all parties. MAR+TSON DEARDORFF WILLIAMS & OTTO By I ~I Jenn fe .Spears, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: February ~, 2005 Attorneys for Plaintiff t CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Motion for Continuance was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO By icia D. Eckenroad Ten East High Street Carlisle, PA 17013 (717)243-3341 Dated: February~2005 ti h? ~ ~ y <~~ YI `+`1 ._I CV-% _ 4 t~ 1_ "'1<.5 i _' ~ , 7 ~ l , . ' ~tTl , _.{ ,.'~ ~ J^} C+l ~~\n'~-' `J R,~ w ; "~ - P:\Pp,E51DAiAPll,H\Genael\Curtrntll0613]6-pal Created: Z/8/OS 11:24AM Revived: 2/8/05 11:2]AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff LARRY E. JUMPER, Plaintiff v. TERESA D. JUMPER, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 01-5462 CIVIL ACTION -LAW IN DIVORCE PRAECIPE Please withdrawal the appearance of Metzger Wickersham Knauss & Erb on behalf of Plaintiff in the above matter. METZGER WICKERSHAM KNAUSS & ERB By: ~~_ ~~ Andrew C. Spears, Esquire I.D. No. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110 (717) 238-8187 Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Plaintiff in the above matter. Date:,.~/n V -~G'7,~!l~iu~ ~S ~ MART DEARDORFF WILLIAMS & OTTO By Jenni r L. Speazs, Esquire I.D. No. 87445 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ~>, e ,.. 9 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, PA, first class mail, postage prepaid, addressed as follows: Kazl E. Rominger, Esquire 155 South Hanover Street Cazlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO BX` ,[~. ~ ~L~Ce1l~j~ Tricia D. Eckenroad ~ Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated:~~~ /~~ Z~5 „f r ;~ r-~ r- ~ _ r-:_e `' _. T , rp~ .._3 il L:~ :. ~ _y W SY~ ' -, n, h("i t_ -.: i " t_1 " ~I it _ ~~ ~ ~~ LARRY E. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW TERESA D. JUMPER, Defendant NO. 01-5462 CIVIL TERM ORDER OF COURT AND NOW, this 1st day of March, 2005, upon consideration of Plaintiffls Motion for Continuance, and of Defendant's Answer To Rule To Show Cause, the motion for continuance is denied. BY THE COURT, .~ennifer L. Spears, Esq. 10 East High Street Carlisle, PA 17013 Attorney for Plaintiff ~arl E. Rominger, Esq. 155 South Hanover Street Carlisle, PA 17013 Attorney for Defendant ~~ a3~01-OS :rc ~~ 5~ ,~.- }t : t~ 1 f~:~"l~~'4~L !e ~~ x ; r+:. V 1.1!'4.11%~`aU~t. u~ ~!~"~~ W~ ~~ri.J~tS`V!'~a-~`~ ,.. ~' ~ ~ ~ ~ LARRY E. JUMPER, Plaintiff v. TERESA D. JUMPER, Defendant AND NOW, this day of rt-'. ~ Lu`. ~. LV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.O1-5462 CIVII, TERM ORDER 2005, upon consideration of the foregoing Answer to Rule to Show Cause, the Motion for Continuance is hereby denied. BY THE COURT, J. Distribution: Karl E. Rominger, Esquire Rominger, Bayley & Whaze 155 South Hanover Street Carlisle, Pennsylvania 17013 Jennifer L. Speazs, Esquire Maztson Deardorff Williams & Otto 10 East High Street Cazlisle, Pennsylvania 17013 ti .' - LARRY E. JUMPER, Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 01-5462 CIVIL TERM ANSWER TO RULE TO SHOW CAUSE TO: THE HONORABLE, the Judges of said Court NOW COMES, Defendant, Teresa D. Jumper, by and through her attorney, Karl E. Rominger, Esquire, and respectfully represents as follows: 1. A hearing on Defendant's Petition for Contempt is scheduled for March 31, 2005, at 2:30 p.m. 2. Plaintiff has filed a Motion for Continuance. 3. Plaintiff and Defendant signed a Martial Settlement Agreement dated Apri17, 2003. 4. Since the signing of said Martial Settlemem Agreement, Plaintiff has failed to pay alimony in the amount of $3,000.00 dollars, pay outstanding medical bills, and has failed to pay uncovered medical bills in full. 5. Defendant has a right to a hearing as soon as possible as almost two years have lapsed since the signing of the Martial Settlement Agreement. WHEREFORE, Defendant respectfully request that the hearing scheduled for March 31, 2005 at 2:30 p.m. not be continued and Plaintiff's Motion for Continuance be denied. ~ ~~ ^... Date : ~ 1 Respectfully submitted, Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717)241-6070 Supreme Court ID # 81924 Attorney for Defendant -. _ , LARRY E. JUMPER, Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.O1-5462 CIVIL TERM CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Teresa D. Jumper, do hereby certify that I this day served a copy of the Answer to Rule to Show Cause upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Jennifer L. Spears, Esquire Martson Deardorff Williams & Otto 10 East FIigh Street Carlisle, Pennsylvania 17013 Date: ~~Z //G r Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717)241-6070 Supreme Court ID # 81924 Attorney for Defendant OaEkBi~;~$tltrYulSbFx~~sl9PeA^Hn3n3SM3Fih~4skN~3 fiW/i +3+13~Ji'~s dswL"' I e+ it ,'. i "'i _,- ..- _ ..Il i~ 3 ~~^}i_% _ ) ?- ~~ i, L~ ~a/f~ /~~ R , LARRY E. JUMPER, Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.01-5462 CIVIL TERM DEFENDANT'S ANSWER TO PLAINTIFF'S NEW MATTER 9. Admitted. 10. Admitted. Byway of further answer, Plaintiff had agreed verbally to pay the fee of filing the title work with Penn Dot as Defendant was without sufficient resources to do the same and since Plaintiff did not pay for the filing fee, the title was subsequently left open. 11. Denied and strict proof of the same is demanded at trial. 12. Admitted. 13. Defendant lacks sufficient information to form a belief as to the truth of this averment. 14. Admitted in part and denied in part. By way of further answer, Defendant lacks sufficient knowledge as to the reasons given to Plaintiff for not returning the vehicle to him. 15. Defendant lacks sufficient information to form a belief as to the truth of this averment. 16. Admitted in part and denied in part. It is admitted that there is a bill attached as Exhibit "B" for $5160.00 but strict proof of payment is demanded at trial. WHEREFORE, the Defendant respectfully requests that this Honorable Court grant her Petition for Contempt, and deny Defendant's claim and award her attorney's fees for Plaintiff s failure to comply with the Marital Settlement Agreement. Date: March 22, 2005 Respectfully Submitted, .--Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 (717) 241- 6070 Supreme Court ID # 81924 Attorney for Defendant e VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Answers to New Matter aze 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:..S' Q~ Ter sa J per LARRY E. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW TERESA D. JUMPER, Defendant NO. 01-5462 CIVIL TERM CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Answer to New Matter upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Jennifer L. Spears, Esquire MDW&O 10 East High Street Carlisle, PA 17013 Date: March 22, 2005 Respectfully submitted, ROMINGER, BAYLEY & WHARE K . Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717)241-6070 Supreme Court ID # 81924 Attorney for Defendant a ~' c ~ ~ -«i ~ ~ N ~ --~ _.. i , ~ C Z E? . i ~ ~~ r f~, }. . ,~ ,,_ _. M~~ LARRY E. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW TERESA D. JUMPER, Defendant NO. OI-5462 CIVIL TERM ORDER OF COURT AND NOW, this 18~' day of March, 2005, upon consideration of Plaintiff's Answer to Petition for Contempt and New Matter, these issues are referred to the hearing previously scheduled for March 31, 2005, at 2:30 p.m.. BY THE COURT, ,,b~nnifer L. Spears, Esq. 10 East High Street Carlisle, PA 17013 Attorney for Plaintiff ,~arl E. Rominger, Esq. 155 South Hanover Street Carlisle, PA 17013 Attorney for Defendant :rc °.:. ~E^k"kt.~&l.~d.,.~...~,. .l'.-.. ... _f,r_ ~ ~xitf4~R~ ~ is~k~6u3"i .,. .... .. ~~, ~ ~ ~ i - un a~ ~~~~ s~ati r~~.*~ ~C ,. ~s' ' i~1C~d ~ ~C3 A~l~s4~ .' ~ ~ ~'x F .; ~ , ., .~. . . _ _ , MAR 14 2005 LARRY E. JUMPER, IN THE COURT OF COMMON PLEAS OF k~ Plaizrtiff/Movant CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-5462 CIVIL ACTION -LAW TERESA D. JUMPER, Defendant/Respondent IN DIVORCE ORDER AND NOW, this day of , 2005, upon consideration ofthe foregoing Plaintiff s Answer to Defendants Petition for Contempt and New Matter, Defendant's Petition for Contempt is denied and Plaintiff is awarded $5,160.00 for fees he incurred for Wife's failure to comply with the Marital Settlement Agreement, plus attorney's fees. In the alternative, this matter shall be consolidated with a hearing currently scheduled for March 31, 2005, at 2:30 p.m. before the Honorable J. Wesley Oler, Jr. BY THE COURT, J. Wesley Oler, Jr.,J. Jennifer L. Spears, Esquire 10 East High Street Carlisle, PA 17013 Attorney for Plaintiff Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Attorney for Defendant F:\HLES\pATAF[LE\Gencral\Ctimrnl\I l3'/ l.1 b.answerl\tde Revised: 3/9/05 2:09PM 10613.4 Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. $7445 10 East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff LARRY E. JUMPER, Plaintiff v. TERESA D. JUMPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5462 CIVIL ACTION -LAW IN DIVORCE PLAINTIFF'S ANSWER TO PETITION FOR CONTEMPT AND NEW MATTER AND NOW, comes the Plaintiff, Larry E. Jumper, by and through his attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby answers Defendant's Petition for Contempt and files the within Counterclaim: 1. Plaintiff is without sufficient information to admit or deny Defendant's address. 2. Admitted. 3. Admitted. 4. Denied as to all subparts. (A). Denied. As stated in Defendant's Amendment to Petition for Contempt filed on January 19, 2005,Plaintiff did in fact sign the title to the Dodge Neon to Plaintiff pursuant to the parties' Marital Settlement Agreement. (B). Denied. Plaintiff and Defendant agreed that Plaintiff would begin alimony payments after some bills were paid, however Plaintiff then incurred over $5,000.00 in fees due to Defendant's failure to comply with the Marital Settlement Agreement, asset forth more fullybelow, which exceeded any amount Plaintiff owed Defendant for alimony. (C). Denied. Defendant was to submit all medical bills properly to insurance before submitting them to Plaintiff and she failed to do so. The bills were never submitted to Plaintiff before now. (D). Denied. Defendant was to submit all medical bills properly to insurance before submitting them to Plaintiff and she failed to do so. The bills were never submitted to Plaintiff before now. 5. Paragraph 5 was omitted from Defendant's Petition for Contempt. 6. Paragraph 6 was omitted from Defendant's Petition for Contempt. 7. Admitted. 8. Denied. Plaintiff has complied with the Marital Settlement Agreement, and for the reasons set forth below, should not be responsible for Defendant's attorney's fees and court fees. NEW MATTER 9. OnApri117,2003, PlaintiffsignedthetitleoftheDodgeNeontoDefendantpursuant to the parties' Marital Settlement Agreement, a copy of which is attached hereto as Exhibit "A.". 10. Unbeknownst to Plaintiff, Defendant had left the title open at Sollenberger's in Carlisle. 11. Defendant then failed to complete the title work because she did not have automobile insurance. 12. On or about July 16, 2003, Wife was caught driving without a license, without tags and without insurance, and the Neon was impounded. 13. Plaintiff was contacted by the police and proved that he had signed the title over to Defendant. The police then concluded that Plaintiff was not legally responsible for the vehicle. 14. The Neon was impounded at Lebo's garage, but Plaintiff was unable to obtain the car because he did not have title to it. 15. Approximately one year later, Plaintiff was informed by the Carlisle Police Department that the Commonwealth considered Plaintiff an owner of the vehicle and that he had to pay to get the car out of impoundment. 16. Plaintiff was billed over $6,000.00 by Lebo's, and ultimately paid $5,160.00 to Lebo's in full satisfaction of the impound and towing charges. A copy of the bill is attached hereto as Exhibit "B." 17. DefendantisresponsibleforthechargesPlaintiffpaidtogettheNeonoutofimpound after April 17, 2003. Therefore, Defendant owes Plaintiff approximately $5,160.00. WHEREFORE, Plaintiff requests this Honorable Court to deny Defendant's Petition for Contempt and award Plaintiff $5,160.00 for fees he incurred for Wife's failure to comply with the Marital Settlement Agreement and attorney's fees. Plaintiff further requests that this matter be consolidated into one hearing, currently scheduled for March 31, 2005, at 2:30 p.m. before the Honorable J. Wesley Oler, Jr. MARTSON DEARDORFF WILLIAMS & OTTO By Jenni r L. pears, Esquire 10 East High Street Carlisle, PA 17013 (717)243-3341 Date: March 9, 2005 Attorneys for Plaintiff i 4 ~a./ f~::XH:C?ie'I" P5'1" s. ~... ~~ Cn rr~ rv rot ' r, vi J1 L1 v ~~ iti Qi v?; ~,{ (~ i:r nz is -+ ¢i "-I CA rq c`5 r~ =7 +v` ny . . ; fj R+~' Q 2. 1 n 1 :~i rtr ci ii1 O `n b r, i r, a' r4~ ii i i ~s m r :~ r,7 z :i m a i a LEBO'S GARAGE ~ TOWINtyLLC NO OOO3SZ 301 w. totaye s~..o1 r, -~ Carlele, PA 17013 (717) 149-4977 Payers (71n 441-y1b0 DATE J_f/Y~3 fl S TIME REQUESTED BY ^~ ,d PO.NO.- A2n~ L NAME /~ SC?`~ ~~ ~ PHONE ADDRESS C ~c?~L.E-iJ~-rv ~~. cm srATE ~i/SPPEacS - - /~ 8~ LOCATION OFVEHICLE ~ ST d- E. P .Y:f .s-r. YEAR,MAKE. L ~ 'rL r'U.AJ ~(; 4c STATE IIC. PLATE NO VEHK:LELD.NO. REGISTEREDOWNER 3~S d rf MILEAGE SERVICE TIME EXTRA PERSON FINISH FINISH FINISH START START START TOTAL TOTAL TOTAL _ REASON FORTOW SPECIALEWIPENT D ACCIDENT OABANDONED OFIATTIRE OSINGLE LINE WINCHING DARKEST OSTOLENCAR GOUTOF GAS ODUAL UNEWINCHiNG ^UNREGISTERED OBREAK DOWN 'IMPOUNDED OSTgTCN BLOCKS DTOWIDNE OLOCK OUT O OSCOTCH BLOCKS O SNOW REMOVAL OSTART O ODOLLY TYPE OF TOW TOWED PER ORDER OF VEHICLETOWEDTO O3LINOIHOISTTOW OSTATE POUCE FIRSTTOWrrM jS ~ O FLAT BED OCAL POUCE GE7 ~ ~'WHEEI UFT DOWNER SECONDTO'N O ODEAIER STORAGE FROM TOWING CHARGE ~;,~ ~ 10 DAYSkS MILEAGE CHARGE PAI DRI~~ERS EXTRA PERSON OCHECK LIC.NO. SPECIAL EXR EQUIPMENT OCREDITCARD OMC OVLSA OAMEX DATE LABOR CHARGE cc NO. .. .. '2~3pr5TORAGE `i OPE RB SIGNATURE DATE ~yy~?A~S~ P'<'Q Cr`' ~-1E vs ~~I-' , A K 6UB-TOTAL AUTHORIZEDSIGNATURE DATE TAX VEHICLE RELEASEDTO DATE TOTAL !."i' ~~ U Towing Service Thank You EXHIBIT "B" VERIFICATION The foregoing Plaintiffls Answer to Petition for Contempt And New Matter 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. ,G' . Jk'.,,net Larry E. Jumper CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy ofthe foregoing Plaintiff s Answer to Petition for Contempt And New Matter was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO y _ U Tri' aD.Eckenroad ii East High Street Carlisle, PA 17013 (717) 243-3341 Dated: March 9, 2005 _. ~s4xnd:~iE2~t~.r+si3~~~~`~d '""'_~~. __~.~ ._d,,:?.~:ems....i-~.3d~~r'a?n~...,,.-.'~'"'u6t~,' _,..,.•«u _a'~_" ~ C~ N 'FYI ...;t °'! T_.h g; f+~~ -^: r. ,~~ c~ ??v _. `L -~i '~ r r~7 r- c,,.t .G" i / /// Q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA .~ _ Plaintiff ~~,,rr~~n Vs File No. c~tU~/~ ~ ~5~1~ ~ IN DIVORCE SG ~iQ,Y)e ~uam er Defen t NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/ defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, ~n or ~ after the entry of a Final Decree in Divorce dated ~~ _ 0 e~W3 hereby elects to resume the pnor surname of I,Un (~~ ,and gives this written notice avowing his /her intention pursuant to the provisions of 54 P.S. 704. Date: ~ 0 U Q ?,l/)'n ~- ignature Pf~ ~ ac y~~ 9ss ~~~a_.71~~t~ Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUN'T'Y OF C-~^ bey/•~..o( ~ On the ~ day of ~uya.s~ , 20~~ before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he /she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. " "-~~- "'~'~ ~~~~ Notary Public ' ao to A~ -Q - ~m 3: ~ ~ ~ m~+ C..Gc.~/~+b . C.:p . 6 _, /~ M-M~r~w~wtN~~riRiN ~ * d.-o 1~~~SOa ~.f N~ ~"~ ~~~