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Home My WebLink About01-07083 'P""" /' <" ,4 , " . SARA L. WORMAN, PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CNIL ACTION - LAW v. : NO. 01 -?0[?3 Q;" J <-r'it.n1 JARED N. WORMAN, DerendanURespondent : IN DNORCE ORDER OF COURT AND NOW, this day of ,20_, upon stipulation by the parties in the above-captioned malter, it is hereby Ordered and Decreed as follows: A.) An injunction is issued preliminarily and until hearing, enjoining Respondent from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property absent ofwrilten agreement between the parties; and B.) An accounting is to be p~ovided to Petitioner's counsel of all withdrawals made by Respondent from any marital assets, except those which have been previously agreed to by the parties. BY THE COURT: J. "f~T~ ,~_~.- . 1'" - j "~f ~~ ""._~~,w._" / ~ ,L SARA L. WORMAN, PlaintifflPetitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. :NO.OI- C'L>~(~~ JARED N. WORMAN, DefendantJRespondent : IN DIVORCE ORDER OF COURT AND NOW, this day of , 20_, upon stipulation by the parties in the above-captioned matter, it is hereby Ordered and Decreed as follows: A.) An injunction is issued preliminarily and until hearing, enjoining Respondent from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property absent of written agreement between the parties; and B.) An accounting is to be provided to Petitioner's counsel of all withdrawals made by Respondent from any marital assets, except those which have been previously agreed to by the parties. BY THE COURT: J. -;""~c _,,'" ~ , ~M .^ ~~, ,T_ ~, ..,-~~ ""on'" 0"' N ,/ . , SARA L. WORMAN, PlaintifJJPetitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 01- 1oR3 C3~~l <-r~ JARED N. WORMAN, Defendant/Respondent : IN DIVORCE ORDER OF COURT AND NOW, this day of ,20_, upon stipulation by the parties in the above-captioned matter, it is hereby Ordered and Decreed as follows: A.) An injunction is issued preliminarily and until hearing, enjoining Respondent from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property absent of written agreement between the parties; and B.) An accounting is to be provided to Petitioner's counsel of all withdrawals made by Respondent from any marital assets, except those which have been previously agreed to by the parties. BY THE COURT: J. -"J.;\H!l"'W~ "f '1' ~ / +""~"""!_,- '. C' I : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 01 - 7oPJ. C'u~ l ~i-Y"L SARA L. WORMAN, Plaintiff/Petitioner v. JARED N. WORMAN, DefendantlRespondent : CNIL ACTION - LAW : DNORCE ORDER OF COURT AND NOW this day of , 20_, upon review of the Petition of the Plaintiff under Pa. R.C.P. 1920.6, it is hereby ORDERED that: The divorce action pending in the Court of Common Pleas of Dauphin County is hereby stayed until a fmal resolution is made in this action. BY THE COURT: , ,,~, ~,", - .". . .. J. , - / -''',-~''''''I""..",",,, < - . . SARA L. WORMAN, Plaintiffi'Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. DI-70R3 C~u~ll~ : CNIL ACTION - LAW ; DNORCE v. JARED N. WORMAN, Defendant/Respondent ORDER OF COURT AND NOW this day of , 20-, upon review of the Petition ofthe Plaintiff under Pac R.C.P. 1920.6, it is hereby ORDERED that: The divorce action pending in the Court of Common Pleas of Dauphin County is hereby stayed until a final resolution is made in this action. BY THE COURT: J. , 1 - - .~,- - ,?'~""= .~~ I"'~~, '""~ /> ,'''''1~'',~1 .. SARA L. WORMAN, P1aintiff/Petitioner v. JARED N. WORMAN, DefendantlRespondent AND NOW this day of - 0---,. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CNIL ACTION - LAW : DNORCE ORDER OF COURT ,20_, upon review of the Petition of the Plaintiff under Pa. R.C.P. 1920.6, it is hereby ORDERED that: The divorce action pending in the Court of Common Pleas of Dauphin County is hereby stayed until a final resolution is made in this action. BY THE COURT: J. ;1'; ~" ~ '-', 'i "-:" . SARA L. WORMAN, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. C,u'(L ~1'>J : NO. 61- 76P-J JARED N. WORMAN, Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or re1~ef requested in these papers by the Plaintiff. You may lose money or properly or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. JF 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. JFYOUDONOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717-249-3166 800-900-9108 ,. --'" "1c^~<,.", . -, " . '~. .~. "'''--':C'''C_c, ' -,. '-', - ,1~--- " . " I"'~-- ~ __.-~., ~--r - ~.~- - , ,. NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. U sted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion do demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importanates para usted. LLEVE ESTA DEMANDA A UN ABODAGO lNMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO, V AY A EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUJR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-900-9108 ---,,-~.~_,_-'l> -~_'''_,___~ c"-' -r,_ , . ""1.:'" .." "".r___ - ." - ";:'>'~ '. p;-:'~-_-_,~-" '_ - ,- . -- ,. ~- -- ~ ,,~-,,-~ SARA 1. WORMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. : NO. 01- 7013 GUll 'T~ JARED N. WORMAN, Defendant : IN DIVORCE COMPLAINT IN DIVORCE COUNT I DIVORCE AND NOW comes the above Plaintiff, Sara 1. Worman, by her attorney, Kathleen Carey Daley, Attorney at Law, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Sara 1. Worman, is an adult individual who resides at 522 Springhouse Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, Jared N. Worman, is an adult individual who resides at 86 Beacon Drive, Harrisburg, Dauphin County, Pennsylvania 17112. 3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six months immediately preceding the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 25, 1960, in Harrisburg, Dauphin County, Pennsylvania. ~- ~,' , -, - ~,-"'. "-' -"-" "r "r - ~ '_',<l__,~" e ','. c - ,"-'--,~t~,", '^,-p .,1 "'0""< ~. _," ,,,,,;',_dX: '1' _. .'-'!~. .~"">'._ ,J_,,~, - . -.= -~".,...,,-y.~i 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its Amendments. 6. The cause of action and section of Divorce Code under which Plaintiff is proceeding IS: A.) Section 3301(a)(6). Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 7. There have been no prior actions in divorce between the parties. 8. Plaintiffhas been advised ofthe availability of counseling and that Plaintiff may have the right to request the parties to participate in counseling. 9. The parties may enter into a written agreement with regard to alimony, alimony pendente lite, and property division. In the event that such an agreement is executed by the parties, the agreement may be incorporated by the Court into the final Decree of Divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. COUNT II EQUITABLE DISTRIBUTION 10. Paragraphs I through 9 of this Complaint are incorporated herein by reference as though set forth in full. ",~ "{ll'nll!R1 "r 11. Plaintiff and Defendant have acquired property, both real and personal during their marriage from the date of their marriage until June 25, 2000, the date of their separation. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. COUNT III ALIMONY 13. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 14. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 15. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard ofliving established during the marriage. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of alimony in her favor. ''-~~i.. ," ""_-_"-'~'o <~'-"'S"',"-:':"[- ~_"-:':-'/_;'_~"+ ,-0"1-,:- ,- '"--c" .~ ",~,_" ". '::"-1;-' ~:~ -,' }'Y"'" ,"~,:-,_.c,r"""_c_'" ,~::"_~.., ,- -, -, ,,'< ," --I COUNT IV ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 16. Paragraphs 1 through 9 of the Complaint are incorporated herein by reference as though set forth in full. 17. Defendant has an earning capacity of at least $50,000 gross per year and has assets which have not yet been ascertained. 18. Plaintiff has employed counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 19. Plaintiff is unable to sustain herself during the course of this litigation. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of Alimony Pendente Lite, interim counsel fees, costs and expenses, until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate. Date: /2}rf!O/ , By: Kleen Carey Daley, Attorney No. 30078 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorney for Plaintiff '~,1101l_, -". _M';'~, . _:<,"_:,1::" ' " I ',- '.<~ - '- " ,-." ;;'<i;'i'f' '-~_~'t:~--"'!f'-"o T'.":',' 'r""] ! ,- VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. BY~~ S L. WO AN, Plaintiff .'",'J'W';;l...... 'c_ >'>-'\ ""-,,,,,:,,,"!'!-'1',"';~'_--;"t'"- " ,,,-~-,, , ~'. ," ,I',~' -" "ec -~, ,j',"_;'" ",' <"~}',,< __1.:',0 >,;,__f',"'-"-<;'" "'<" '~.--','<:':~-;--":;:_,~'f'?~'-~ . -~"Y--.- . ".,,--,0--- -v,. ,. I.." ill "--"""-'-'-'-'.'""""'"-""'-~",,":,;,.'i;';'.-":-'(;-lr- ,., . ,",,' 1i:~-~--\JOt-' e:}i't'-;ViF_''i:'lt-;;-~1;:'iIi'?,::~r'V+:;::i~~~~I~~:.,*~:i l ~ ~ ~ "<l 1_:-::: ~ <~ ...... ; ~ "l ,-.') ~ ~ ~0 ,0 ~ " i~J ~ .0 CIi & 8 & c ~ cu 'oj re "() i' -.... YD- I \ \ ~ " (;) Gv ~ :"-) - ~.>' J --( ::) ~ -.' &: r'" Yf I, ;7-~-~,:-;_"e::,;"::'",^,Y~"\;r--_'-- ,~-, ''''_ +,/~;-,~_;,JIf ~~---H.~E"'-o'--- 'W_'""-- (0-,- ';_---'~ JV_-__~- " ~:lt..u. ,0 ~ ~:'_~:y--'"' ~~>/::':': ~ _~ ,t_'_T-,;,-J~"!jl.~! .~~ill!~i;f!.!I)" q,W,',_~",U14, _ ?^1J1 'D-",.It" <- ':e:",.,,~~-_-n1~l:t.C1 :'< ;'J$:!,:",:,~~,.~._ k.- ",;, " -~--~;( SARA L. WORMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW JARED N. WORMAN, Defendant NO. 01-7083 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR SPECIAL RELIEF IN THE FORM OF AN INJUNCTION PREVENTING REMOVAL. DISPOSITION. ENCUMBERING OR ALIENATION OF PROPERTY UNDER ~ 3505 OF THE DIVORCE CODE AND PA.R.C.P. 1920.43(A) ORDER OF COURT AND NOW, this 4th day of January, 2002, upon consideration of Plaintiff's "Petition for Special Relief in the Form of an Injunction Preventing Removal, Disposition, Encumbering or Alienation of Property under 9 3505 of the Divorce Code and PaRC.P. 1920.43(a)," both parties are enjoined from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property absent a written agreement between the parties and both parties shall provide to the other party an accounting of all withdrawals from any marital assets, except those which have been previously agreed to by the parties. A hearing is scheduled for Thursday, March 14,2002, at 9:30 a.m. in Courtroom No.1 in the Court of Common Pleas of Cumberland County in Carlisle, Pennsylvania, for purposes of considering whether this order should be continued, modified or vacated. BY THE COURT, J. -"R"li"'f liOI IY ~ ..,,,,,1"__.,AJ!l1x}t_nJ:~~Il\T_'W,, _ ,-~"L-~ ~." ~~.,~~-~ . '''';.A)'''':;rP'if:-'~F'<Kt';'1;~;9,; t~;"lt-'$~~;iijj)~~4#%;~4~;t~!2E?i?~1tf1fg~k: V!fIf\f/i1,~SNN3d I I N'i(Y' r),_.,..,.l,nWn.'"\ 1\- ! 'L"_~' ',~;. '\.' ),::'/\,i IV :i" I ZS :O! i:" , ii'; ;',- '''.' t < ,~ ,C';'l '1_ f'f ("0 f.HvJ.:. ;.j j!h. :""--~":,,,~~~~~~~~1~~~-\f~n~~0t"'fr.'1"':Cp!'li*"i1T!li'!f.:'W-Q;~~~_~l&JlI~~_~lU\'::' ,.',,"'" , {:~ A<.athleen Carey Daley, Esq. 1029 Scenery Drive Harrisburg, P A 17109 Attorney for Plaintiff /raredN. Worman 86 Beacon Drive Harrisburg, PA 17112 Pro Se Defendant V Jeanne B. Costopoulos, Esq. 1400 North Second Street Harrisburg, P A 17102 Courtesy Copy ""<~~-''''''' .~, ,."~~-.'" -, - -,~- " ,- ^~,~ .,...- ~ ~ ~/o?- \,,: \,D o 2 -~'-' "" ,,' ,k',____ ".', , . ""'''^'-,'.~ .r SARA L. WORMAN, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA : CNIL ACTION - LAW v. : NO. Ol - 7()1<J GI'U'l-l 'L~ JARED N. WORMAN, Defendant/Respondent : IN DNORCE ORDER OF COURT AND NOW, this day of , 20_, upon stipulation by the parties in the above-captioned matter, it is hereby Ordered and Decreed as follows: A.) An injlU1ction is issued preliminarily and lU1til hearing, enjoining Respondent from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property absent of written agreement between the parties; and B.) An accolU1ting is to be provided to Petitioner's cOlU1sel of all withdrawals made by Respondent from any marital assets, except those which have been previously agreed to by the parties. BY THE COURT: J. ;;;'-!~-"--_j.< -'-"'~;"-'~">:-P"''>~,~-':!"10'.'-:''-' 'ii- '. ".."-',',. 'rh., 0" _~ - '. 1,'" ,~- ,^, _.' _ ~ T. ~ '" .. I~ , ~",' . v. : JN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ~NO. ot-loM C?lu'<l T~ SARA L. WORMAN, Plaintiff/Petitioner JARED N. WORMAN, DefendantJRespondent : JN DIVORCE , , ,:;' PETITION FOR SPECIAL RELIEF IN THE FORM OF AN INJUNCTION PREVENTING REMOVAL, DISPOSITION, ENCUMBERING OR ALIENATION OF PROPERTY UNDER Ii 3505 OF THE DIVORCE CODE AND P A.R.C.P. 1920,43(A) AND NOW comes the Petitioner herein, Sara L. Worman, by and through her counsel of record, Kathleen Carey Daley, Esquire, and petitions the Court as follows: 1. Petitioner is Sara L. Worman, an adult individual currently residing at 522 Springhouse Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Respondent is Jared N. Worman, an adult individual currently residing at 86 Beacon Drive, Harrisburg, Dauphin County, Pennsylvania 17112. 3. Petitioner and Respondent are husband and wife, having been married on June 25, 1960. Wife is filing a Complaint in Divorce under Section 3301 (a)( 6) concurrently with this Petition. 4. The Plaintiff and Defendant, as tenants by the entireties, are owners of certain real properly and other assets, which, although marital, are titled in the name of Husband individually and Wife individually. 5. A major aspect of the marital estate is comprised of retirement and investment :)l~,.~TI_:iJ. "., .,~,- .'..'..4_ ,'~"_.,."_," ,'."_. _.",,~,. >:'".> _ ~ ~" ~,''''__'_~ .,~_',"",_.,~", "'""~_'E> -.^~, ."",., - ,_,(_,' , "0 :"-"'-"'.;( '--~c-'~"" ".' ~~, ",.r'_~" ~,. "_~ .. ~," ,""-,_. "-"',."'-"!".""-' . " ~=~""" . accounts, many of which are titled in Husband's name. Contrary to the written agreement of the parties and without any infonnation to Wife, Husband has invaded said account so as to distribute more than $3,000 in funds to himself within the last sixty (60) days. 6. Subsequent to the removal of these funds, Husband filed an action seeking a no-fault divorce in the Court of Common Pleas of Dauphin County. Wife has filed a fault divorce complaint on the basis of Husband's adultery and indignities in the Court of Common Pleas of Cumberland County. 7. Husband elected an early retirement from his position as an engineer with AMP, Inc. and has now chosen to take a part-time position with very minimum income. 8. Wife is employed as a part-time registered nurse through the Visiting Nurse Association of Central Pennsylvania and Hempfield Counseling Association and is attempting to provide for her own needs on the basis of her income. 9. It is believed and averred that the actions of Husband in dissipating these marital assets will be contrary to the interests of Wife and in violation of the obligations owed by Husband to Wife under the Divorce Code. 10. Wife is in possession of the marital home which has substantial value, but which is subject to two mortgages which they are paying. 11. Wife has a legal right, title and interest in this property and is asking the Court to secure its value so that it is available for the purposes of equitable distribution. 12. By selling, transferring, disposing, encumbering, concealing, removing or alienating these funds without accounting for the same to Petitioner in order to defeat equitable distribution, g<~- o " =_k,~ -~,-""=.~~'''''=~,~. ,~:O=,,_ ","," .~,_.,..,."-~._,''''',,,_ ,__"~',~_" . "<.-'" ,~,_,_"_ '_~H,_',",,"O_.,.w ,^ __, _ ., < ~,_C ,~ "." _ 0, _ ,- jf v Respondent will wrongfully and intentionally prevent Petitioner from exercising her right in ownership in said property. WHEREFORE, Petitioner prays for equitable relief as follows: A.) that an injunction issue preliminarily and until hearing and finally thereafter, enjoining Respondent from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property absent of written agreement between the parties; B.) that your Honorable Court issue an order requiring an accounting of all withdrawals made by Husband from any marital assets, except those which have been previously agreed to by the parties; and C.) such other relief as your Honorable Court may deem appropriate. Respectfully submitted, DALEY LAW OFFICES By: .J thleen Carey Daley, Es uir A torneyI. D. No. 30078 1029 Scenery Drive Harrisburg, P A 171 09 (717) 657-4795 Attorney for Petitioner c\_J-;.-L __~ '" u~,_ A^,_", ""~'r"', ',-,,-'t'," '_,_,~.-,"" I,,"'___~_,'__~"-',__" _,__ ~,_. H.._'~" . '-.__' ,'"""" "'____~._..""',I_',' ~,". '-'" ~', '--.-" .- -' "'''j[ # ' . VERIFICATION Upon my personal knowledge, information and belief, I, Sara L. Worman, do hereby verify that the facts averred and statements made in the foregoing Petition for Special Relief in the Form of an Injunction Preventing Removal, Disposition, Encumbering or Alienation of Property Under ~ 3505 ofthe Divorce Code and Pa.R.C.P. 1920.43(A) are true and correct. I understand that false statements or averments therein made will subject me to the criminal ": '-1 :11 :"1 penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. Date: ..::t~~ II ~ , B, ~HJ~aU S 1. WO AN /-'Y~J "',-"",=r_.,.,"~., ""~"~"" ,~. " ~_,___~_. ~~._.__,~y,~ >._,,_' .<<,"~",p~ ~ ,_""",_'."_~" ~~ '. '.', _ '. ~,,~ "__ _ _ ',,,",,,V-'" ,,".' _,'. "-"-'~ ~ ,_,,~_ A,' "~__ _,,= ,~, .~;, =~. _.... ,=. ,",' "--"-' ~ t ~ --~ ~lt~-..r~,f!l ~~ __ .. ,,~ ,., ,tOw. ,.".<,.-, __~ ~~., IT ~l"' ~~.~~ -- ~';J.,~,,"p'p ~.' 40,' "'\ ,N,:',rU"~' '91fim: -fjiti~"f'1.1~:~:irCW"nr*j"':.f:' ~~3';"1if""~ . .. n i: c- > , '.-:1 , {:-.: ;.........., ''1 ::) , r ,~) -<; ,,_,"~~~!~~.\t..; ,~, ,,;'i[~~~~~~~;,.-' .. , SARA L. WORMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 01-7083 CIVIL TERM JARED N. WORMAN, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Jeanne B. Costopoulos, Esquire, do hereby accept service of the true and correct copy of the Complaint in Divorce on behalf of my client, Jared N. Worman, the Defendant in the above case. Respectfully submitted, Date: 111/dJ (j~ Jean6e B. Costopoulos, Esquire Attorney No. '17 J5 1400 N. Second Street Harrisburg, PA 17102 (717) 221-0900 Attorney for Defendant L.-:>-:.:=~.",,_,._ ,,}.,_ "" '.e,.""~' _" .'""-<<',.,O"-'O't.. ".,.'~ ~__., __ _ ,~__"t,<;!f,""-',__""",._ '_C'.,' ~ .' ^~:;^.',e", ('<""., -'.CO' ,t,~ -x ',' ." <". A, ."~" '~~"_', _, .,. __, , '^"~ .,~ "., ---.'"1. ' ~ "~.<,_""'" c.,~"",",-,, "',,0'.' 00'"" "^,. <'_< = ,,-- :".T1"'"'~'~''' ., , ~,__ ""_F'r"" ~ ~fl.IDi~[;,_, __ ~~" ~.~, ,_ "'~~ ^"~,"~-""", __'v -'-.' -r]"::: ~~... r'~:: d'::~C >~:;; <~ -j -, -- ~ut' ."~:"~~f:~fjt~~ ;".fW~(.ti.f)lWft:N'!'f'~~ C) C 41 '-7\ !.:__.J !"'-.:' ~.-'. r;'! l'';) r-.) ,~-".f.I_. ,r .;__,~~.~~i\;~1,f>~~'>11~.~~~; " :.~ I , SARA L. WORMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW JARED N. WORMAN, Defendant NO. 01-7083 CIVIL TERM IN RE: PLAINTIFF'S PETITION TO STAY COMPLAINT IN DIVORCE UNDER RULE 1920.6. MULTIPLE ACTIONS ORDER OF COURT AND NOW, this i ti1day of January, 2002, upon consideration of Plaintiff's "Petition To Stay Complaint in Divorce under Rule 1920.6, Multiple Actions," a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, d( esley Oler, )Kathleen Carey Daley, Esq. 1029 Scenery Drive . ^ \ Harrisburg, PA 17109 tap-U.o 0)~ Attorney for Plaintiff " 1 L ~'f.? /_ '" -0"- hared N. Worman 86 Beacon Drive Harrisburg, PA 17112 Pro Se Defendant heanne B. Costopoulos, Esq. 1400 North Second Street Harrisburg, P A 17102 Courtesy Copy :'.L.UJ i . ! Ita SE ~~~Rijt_J , VINVA-JASNN3d j"N1nry, r" ".J-'LI~- """' I .j<,j "n\:;1 !'--!:!d!AJnO e; ;0I1,,:~ iJ- iHW 20 __I.r-~ ",\" '^ '~'I' ~ ' ",""-"> ,. '\.. ',,",'c ''i~'n -'Milt11"f'" "'rd'-"1~'tft~:'iff(f'ii<~I~;Yl~fViiW:1;1? i :1 :,1 i 0 ~ :;1 " i'l "I !-! :-1 ::: " ;1 !'I 'i! !i~- :,'1 ~"""" J" 1J,F&."H'\~~IM\'l!1'll~~ifl/t~_il!l!!'i 'W"-.~,,,"A!I!!I!!~,'g-"'d_.",_~'W''\if'i'v:.,,,,,;":-,;,,';,;;-;fo''::''1_'''_''~O:;;\-,"._","'P;~';;J'.~~Il'!~I~,l;i,-;1;'l3\~"~~').\'~!"_"<\<i>1:'Vi[')!'F~;~liij'!!w,ir~!ll"!;W;,!-,",i!, '-' v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :No.61- 16PJ. CI(.)~C 1€JU"') SARA L. WORMAN, Plaintiff/Petitioner JARED N. WORMAN, DefendantlRespondent : CIVIL ACTION - LAW : DIVORCE ORDER OF COURT AND NOW this day of , 20_, upon review of the Petition of the Plaintiff under Pa. R.C.P. 1920.6, it is hereby ORDERED that: The divorce action pending in the Court of Common Pleas of Dauphin County is hereby stayed until a final resolution is made in this action. BY THE COURT: J. ;")i:, ., <". '.'; --, n',,,,,,;:e,'-,,''''_ "~"~,",'.'''.'''''-, '__..'-,. "-'~.; ~'-', :',," '\:"'v~ '~''-', .. , . ,;, ,T e, ',"'_ ~ "..' - - . -, ". , " - _ ~r. :'.iiY' :'"'' SARA 1. WORMAN, Plaintiffi'Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. Dl-7()10 0'; u ~ ~ <-r'itUlt. JARED N. WORMAN, Defendant/Respondent : CNIL ACTION - LAW : DNORCE PETITION TO STAY COMPLAINT IN DIVORCE UNDER RULE 1920.6. MULTIPLE ACTIONS 1. The Petitioner is Sara 1. Worman, the Plaintiff in a divorce action filed to the above- captioned term and number in the Court of Common Pleas of Cumberland County. 2. The Respondent is Jared N. Worman, the Defendant in this above-captioned divorce action. 3. The basis for this Petition is a request that the divorce action instituted by the Defendant on November 27, 2001, in Dauphin County be stayed as the result of this divorce action being filed in Cumberland County. 4. The parties have been married since 1960 and established a marital residence in Cumberland County in approximately 1974. 5. They have resided at 522 Springhouse Road, Camp Hill, Pennsylvania 17011, continuously since that time until Husband vacated the marital residence in July of2000 as the result of his extra-marital affair with another woman. 6. The Petitioner continues to reside in the marital residence along with her elderly mother, an equitable owner of the property. ':-'~~d l . ,..,~ ,; r';\-' -- ..~ .- :-";C"''',''_,' ,,_-_to' -- -- "r,,} Z--"'~- ,'--'-; ",' ---.,--' ,~ 1~ ,- ," ----'~. ."-~ .'. , H __,~, 0";' '. 7. Husband has recently rented an apartment in Harrisburg, located in Dauphin County, Pennsylvania, but it is not believed that any other marital property is located in that jurisdiction, except two burial lots. 8. It is the contention of the undersigned. that the counsel for Husband chose to file this action in Dauphin County attempting to obtain more favorable treatment on alimony and other issues by the Dauphin County Court than if the matter were to proceed in Cumberland County. WHEREFORE, Petitioner respectfully asks this Court to find that the current action in Cumberland County shall be the basis for this action in divorce and that the action now pending in Dauphin County shall be stayed and/or terminated at the discretion of the Court. Respectfully submitted, DALEY LAW OFFICES Date: 1'2/14(DI ( By: athleen Carey Daley, s Attorney LD. No. 30078 1029 Scenery Drive Harrisburg, P A 17109 717-657-4795 Attorney for Petitioner -'il~~_)!, ". '"'''''''_:'''!''''~~_~?,d",,~_<''',,''"<'._ >,;',i",,,+,"-,,~"_A,-\'f'''''~ '"'~'" ,'L' ."_",_""<h__".,-__'~,,'ch',, ''',' ,-:- "- " ,,-, h ~r. _^~e".' --;~ , _, _'__' "-"-,,.,,~',',"""Y-_"_"'_-C-"_~~ryJ ,.,,,. "'_;""?_"_ . 1 ;,~';",(f' ,.." ~ ~,~,i>!_. .. VERIFICATION Upon my personal knowledge, information and belief, I, Sara L. Worman, do hereby verify that the facts averred and statements made in the foregoing Petition to Stay Complaint in Divorce Under Rule 1920.6, Multiple Actions are true and correct. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. Date. ~~J~) SARA 1. WORMAN By: ,"- C"_'_'>-_' 1"'--";G'<,--,---~,-:-___.v'" " . --,<!,'::.' "~r' J" ,~"~-_ j,"F_,:,' ":",: " ".. . ~ ",' " --'"-"',," --, ... '~-"" -, . ,,", .~-, ~-" ~" ,- ,~~, ,,'!">:' ._. _<" <,_;"__'" -,1, f !iilllJUl- ,W.' 'i,; ."... "N''''. .'>".,,"\,,',',"'>",,",.... ,... ,",,' ~" '.,,, __..' ~k'~'" 'c''''''___-'''''',^,"=.~.,_<" ^_w . -" ,c:'.,)"", ,,"",;,c~" lrLf'i'''t~mfllifJiTtjJIj'::~''7rrc->'~e,.'\ .. ~--"_~,,., ':ft~;;/.:'.y,'t(,~. '....i.'~."1(._J',' ,)X ~!~,' !-~.~~~~ ~,~. ,:i.- ,---,-;-" r:::;i'-'- ,,'"-:;, (- :t~ ;~; o r'-- =<! \:;,;:' ;".1 t:~) :::; @I;,~J: r","", -.dit_~'!n~:~mr , .'..iI".""" " __J ~: I, .~l!,~ll!!i~'/: ,. ,.,,_ .-::,_.',',-,,',,"\1\r .yifi'.'-' -. SARA 1. WORMAN, PlaintiIDPetitioner v. JARED N. WORMAN, Defendant/Respondent ORDER AND NOW, this 2.t.. tL day of IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 01-7083 CIVIL TERM IN DIVORCE ~L~v~') , 2002, upon consideration of the Petitioner's Motion to Make Rule Absolute, it is hereby ORDERED that the lPi.t~ !>~2..ll r"lbt ~ 1..t.tt.J dfLe... .nlJo, 5~~'i~1 c.,V. ZbO!OV ~ dIvorce action now pendmg in Dauphin County 8e ..itl.d._..I\ and that the pending action in ^ ~ Cumberland County be the basis for jurisdiction in this divorce proceeding. o..tlQ. ~Q.sbpou.'o.s Cop\es P1o:.\eJ . D ~\~ ? Q,'l.;l~'O~' ~ BY THE COURT: . '~I;;'t:~t 'C,.,,,, WJ'~'~'~C"":"<J':'" ., _'c' ,:"(--,,,_,__~, :--'.'~",t '",~\, ":~;;--,'=-.~",._,,.~, "', ",:~~'_;;; ___ ',"".",'e',.,,~,~' "'-! ',y, .~__" -"':""~~"::'::'\'~C.7~ __ ",~ "".~.': 'O.c,." '. ,'" ,", ' ,", ''''", > _., ,',_"'" ~_ ", '_";" ,'~~,'F~' .~" '; " ",' o I') ..." r" tP r..;> cr' o '-n ~ -~ - - :]~-'n !n-;::;:::, _.,.,,'n .-. ~ :----1 ,,---"-- ~~1Q, -;,,1.;:,,_1 ~~C) .-:...,,,, 9 ~ ::< "I' '$'&'~' . " SARA 1. WORMAN, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 01-7083 CIVIL TERM JARED N. WORMAN, Defendant/Respondent IN DIVORCE MOTION TO MAKE RULE ABSOLUTE AND NOW, comes the Petitioner, Sara 1. Worman, by and through her attorney, Kathleen Carey Daley, Esquire, and avers the following: 1. On December 18, 2001, Petitioner filed with this Honorable Court a Petition to Stay Complaint in Divorce Under Rule 1920.6, Multiple Actions. 2. On January 4, 2002, the Honorable 1. Wesley Oler, Jr., issued a Rule on the Respondent to show cause why the relief requested should not be granted. Said Rule was returnable within twenty (20) days from service. 3. Twenty (20) days have elapsed and the Respondent has not responded to said Rule. ,.~;:;~~u:. ""'~',~ '~"" ','011 ;:":'$i~'l~,,_'c "--"".",~~';""^".,,._~-< "'v-, ,~",-~,,-~'''','''- ,- ". -.""_"OC"',"_1""cy",; '.'. ,,"''"?<- _.,_""._C"""", ;~':'_, <""C""";''-'. "T,_ ,"''''' O' ,". --:;; "~-~,,,--~<"": .~'--'""'~"'_"",'T<:",",,(, ~ ,_..,~ ""'0[,." "." ' - 'T ' -, '.y_.- WHEREFORE, Petitioner respectfully requests this Honorable Court to make the Rule absolute and issue an order directing that the divorce action now pending in Dauphin County be withdrawn and that the pending action in Cumberland County be the basis for jurisdiction in this divorce proceeding. Respectfully submitted, DALEY LAW OFFICES c---- athleen Carey Daley, - Attorney No. 30078 1029 Scenery Drive Harrisburg, P A 17109 (717) 657-4795 "",,,]!(1;' .D. _ , "~',:,F',,=/:",_~, '-',,1' ,.,'?"c,,;:,rO";;'" ",' ',. ""~',,'!'7'''C;'"';,:::,,>~,,~ ,.' '0"'- ~r.' "" "1'"' ,,~ ,<"," "" -.'. "'~_"," c.--' -', ',d" c ~': _ ~'"'. ""f'l', ,^>h>.O, ,. " "'"reF",' ,'J,'" . ;"",,-,,,,.,--' I'" "'-,," ~"~ ",' -.-,., .. ""'-'lliIIil.'iiiIl,f' r' ~::.~ ::':) -- [-..,) C~i ~'~"i .~,., ,- , -< ( ::J ~. J.LB;J~";'_ _"~ ' .~;. ~ ",".1~'fl'~,,"~-_,". '.---.~~,7~. ," 7' '-? ~."".~:;.,r!.~~~"""":4"~->:f~\~~~'M..q<:~'W-!l:$':,.. ). "J~~~~., ~,!:: SARA L. WORMAN, Plaintiff v. JARED N. WORMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 01-7083 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 6th day of March, 2002, upon consideration of the attached letter from Kathleen Carey Daley, Esq., attorney for Plaintiff, the hearing previously scheduled for March 14, 2002, is rescheduled to Thursday, May 30, 2002, at 1:30 p.m., III Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. Kathleen Carey Daley, Esq. 1029 Scenery Drive Harrisburg, PA 17109 Attorney for Plaintiff Jearme B. Costopoulos, Esq. 1400 North Second Street Harrisburg, P A 17102 Attorney for Defendant :rc -~~- ,'"-'- , ,. " 'f." " " ".n,"'__ , ,-,"," --' , BY THE COURT, (J c> \'...:; ~ ~r; -1'::; f7i '.- -",~ o:;~~', '~,;') 6ff"- ~ Bt~ ~~ ?Cl ::::.~ z() C"" $(~ ~ 3, ~~ ..3~!,-b.:z.., ~. , ~. , .,--- ,h'\ . .-'1 "'--0-' \() " -1--1 '.-.-' ,-;.~) {~rn ~:9 ~ , DALEY LAW OFFICES 1029 SCENERY DRIVE. HARRISBURG, PA 17109 . (717) 657-4795 . FAX (717) 657-4996 March 5, 2002 The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: Worman v. Worman No. 01-7083 Civil Term Dear Judge Oler: A hearing has been scheduled on my Petition for Special Relief in the above-captioned case for March 14, 2002, at 9:30 a.m. I am scheduled to be out of town that week and respectfully request that this hearing be rescheduled. I have contacted Jeanne B. Costopoulos, Esquire, attorney for the Defendant, and she has concurred with my request. Thank you for your attention to this matter. KCD:pap :;:Q~::::U.x ""'= C"" OW" u r e U cc: Jeanne B. Costopoulos, Esquire Sara 1. Worman MAR -6 ~ ,002 i-!'~~-"",<,- ,~.~" .,-":'~,--__''',''?'r'',".,, - ''',,~',-,'''',~,;'''C:'~', >,."~, '<''-''-__'.'1.~~,>~.C_'''''' ' 'Z"c',!"""'___ ~'" 0"';"""'-,',"~e",-- ,,".,,~ .' <.~.""--,~ .-..=,,,""",~,~"--~ ," " - ,~" , ~, " ~,~.. . SARA L. WORMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JARED N. WORMAN, Defendant No. 01-7083 CIVIL TERM ORDER OF COURT AND NOW, this 30th day of May, 2002, upon consideration of the Plaintiff's "petition for Special Relief in the Form of an Injunction Preventing Removal, Disposition, Encumbering or Alienation of Property under Section 3505 of the Divorce Code and Pa. R.C.P. 1920.43(A) ," and pursuant to an agreement reached in open court in the presence of the parties and their respective counsel, Kathleen Daley, Esquire, on behalf of the Plaintiff, and Jeanne Costopoulos, Esquire, on behalf of the Defendant, it is ordered and directed as follows: 1. Both parties are enjoined from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property absent a written agreement between the parties, except for those withdrawals which have been previously agreed to by the parties. 2. Each party will furnish the other with their respective 2001 year-end IRA statements showing all withdrawals made during 2001. 3. With regard to 2002, the parties shall ;...TJI{,~'~ , , . , <, ." " .,"" .<= " - ."Co,..",. .-,.', " '.' '']j ~ ~" . ',' , '" ',' . "".', . ',' _ 'd ,~ 'I~ , '~~3~1"^~:"" . . . furnish each other with a copy of each monthly statement received for the IRA account as each monthly statement is received. 4. This order is entered without prejudice to Plaintiff's right to bring an action in contempt seeking additional remedies, including attorney's fees and costs, for violation of the temporary order. By the Court, J. ~athleen Daley, Esquire For the Plaintiff C' ~ ) ~f( Rit ~eanne B. Costopoulos, Esquire For the Defendant wcy . ,.. ,. ~ ".-". ~ , . ~,~ "."-1--"',-~ @ c,. ..__ .c' ...IL.. ' \l'I~;VI'\-I.l(',N. "J;; , ".1 """ r,_c j 11\lllrJ:~l (l:'"r(n~..J::1p~f'!I!"I," IU't '-_ -' __, ,. _,,_,'.-,J'{ oJ 0'1 :O! ~W 81 imr 20 AL' '1(1',1:,," i.',.' Q'I ~.i ;-..1: I..!,,\.~,.hj 3C)L:!:lO-Ojll.~ ::JO ~ , ~~. "",^>.~'.....~"'r' ;""~~ " " ,.c_", --->' c' o,'~'''&c'lc+-''~'' ";"'",Y'~~;i<~frM:~rW'i";;'~\W)t~'-7 " . 1:-s 8// 1 :-' I'" ,., ., r"lt""'~'f'."""J, 1 , Er..),~~_ "..c,,,,~~,,,,,,l!IJflrlJ~~~~'",#~'i',^~tl4,~i'!:'ip;{'W"''1f,i~@);1~,!m~~K~IW~!!Jf~IJ~.M.""I'A'llJ~0' ,~."!;\' SARA 1. WORMAN, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 01-7083 CIVIL TERM JARED N. WORMAN, Defendant/Respondent : IN DIVORCE PROPOSED ORDER OF COURT AND NOW this day of , 2002, upon review of the Petition for Contempt Under the Provisions of 23 Pa. C.S. due to a Violation of an Order of Court of the Plaintiff Under Pa. R.C.P. 1920.6: 1. The Defendant/Respondent, Jared N. Worman is guilty of contempt; 2. Legal fees are assessed against the Defendant/Respondent in the amount of $1 ,400, which shall be paid to Kathleen Carey Daley, Esquire, within ten (10) days ofthe date ofthe entry of this Order. BY THE COURT: ~ir~~' J. Wesley Oler, Jr., Judge '~~~Y'""'"'" F~"~., '."__', . r'~=^ " ".."..' ,.u. ,.,~ , - - 1- ~~ ill!, SARA L. WORMAN, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 01-7083 CIVIL TERM JARED N. WORMAN, Defendant/Respondent : IN DIVORCE PROPOSED ORDER OF COURT AND NOW this day of , 2002, upon review of the Petition for Contempt Under the Provisions of 23 Pa. C.S. due to a Violation of an Order of Court of the Plaintiff Under Pa. R.C.P. 1920.6: 1. The Defendant/Respondent, Jared N. Worman is guilty of contempt; 2. Legal fees are assessed against the Defendant/Respondent in the amount of $1,400, which shall be paid to Kathleen Carey Daley, Esquire, within ten (10) days ofthe date of the entry of this Order. BY THE COURT: J. Wesley Oler, Jr., Judge il',~:i!L~"Il"! ~)1J, -""f' ~", ~>,'<.'" ~.~~ "'.' " "1" "--,.-" '", .~ " Ell ..- SARA L. WORMAN, Plaintiff /Petitioner : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 01-7083 CIVIL TERM JARED N. WORMAN, DefendantJRespondent : IN DIVORCE PROPOSED ORDER OF COURT AND NOW this day of , 2002, upon review of the Petition for Contempt Under the Provisions of 23 Pa. C.S. due to a Violation of an Order of Court of the Plaintiff Under Pa. R.C.P. 1920.6: 1. The DefendantJRespondent, Jared N. Worman is guilty of contempt; 2. Legal fees are assessed against the DefendantlRespondent in the amount of$I,400, which shall be paid to Kathleen Carey Daley, Esquire, within ten (10) days of the date of the entry of this Order. BY THE COURT: J. Wesley Oler, Jr., Judge ";<~W\~ ~ " _ ',~ ., " ~"." I"~ , d~.",~.,~,~l.' .. ~. "'" SARA 1. WORMAN, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 01-7083 CIVIL TERM JARED N. WORMAN, Defendant/Respondent : IN DIVORCE PROPOSED ORDER OF COURT AND NOW this day of , 2002, upon review of the Petition for Contempt Under the Provisions of 23 Pa. C.S. due to a Violation of an Order of Court ofthe Plaintiff Under Pa. R.C.P. 1920.6: 1. The Defendant/Respondent, Jared N. Worman is guilty of contempt; 2. Legal fees are assessed against the Defendant/Respondent in the amount of$I,400, which shall be paid to Kathleen Carey Daley, Esquire, within ten (10) days ofthe date ofthe entry of this Order. BY THE COURT: J. Wesley Oler, Jr., Judge :-,~~""'-"~." ~J!'" ,"~-f ,_", '_'~""_P~~'I" "" ~ -": ~- t ,,<.;~ ; SARAL. WORMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW JARED N. WORMAN, Defendant NO. 01-7083 CIVIL TERM ORDER OF COURT AND NOW, this 3rd day of September, 2002, upon consideration of Plaintiff's Petition for Contempt under the Provisions of 23 Pa. C.S. Due to a Violation of an Order of Court, a hearing is scheduled for Wednesday, November 13, 2002, at 2:30 p.m., in Courtroom No. I, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Kathleen Carey Daley, Esq. 1029 Scenery Drive Harrisburg, PAl 71 09 Attorney for Plaintiff Jeanne B. Costopou1os, Esq. 1400 North Second Street Harrisburg, P A 17102 Attorney for Defendant . ~ q,O<f.D:P ~ 9-. :rc i;~ ,e-<, i ,< I.', ,:~~t,v~=<,,.p;lf .<~ . < < ,,-,," "'" ",,',,"''', .,,,",,-_ "~I'~h" ,,' ~!MiIilllml!lJllRl~l'm?l>[ , ~ - -~. \ I" V/M"'lp /lJ.jII[JO;',' ',(SiVN:J I "L' Ot\/iP'i.l,""'U:' S'J:/ '.}d" """. :::rgYvno ~'t p ,_ ',' n~ oJ'- -. J..!::it/1QFC,' " v co ,~'cL&!o~::L;"",', ::;'C7 -..Ii::"', '1L% ;;5 f!jf.J./ ,I "11 !:"I '-:':! - "I . ~.~,,= ....'.0 ''''~ = ,~:r,~f;t&i',~2i'~~'i!>$j","'H."".';f";';--;'i;"'Y' '';<;;1'''';;' ~\i~""",~~~_i~~."".~"",,0i?:~!_ i'_1 ",,~ SARA 1. WORMAN, Plaintiff7Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. 01-7083 CIVIL TERM JARED N. WORMAN, Defendant/Respondent : IN DIVORCE PROPOSED ORDER OF COURT AND NOW this day of , 2002, upon review of the Petition for Contempt Under the Provisions of 23 Pa. C.S. due to a Violation of an Order of Court ofthe Plaintiff Under Pa. R.C.P. 1920.6: 1. The Defendant/Respondent, Jared N. Worman is guilty of contempt; 2. Legal fees are assessed against the Defendant/Respondent in the amount of $1 ,400, which shall be paid to Kathleen Carey Daley, Esquire, within ten (10) days ofthe date ofthe entry of this Order. BY THE COURT: J. Wesley Oler, Jr., Judge li;,~])~J ,..-- ,-,_~ "',,''''7-'1''','''''''-'.--.,-... ^'___'."''''''''''''"''''''__~,.."I.'''''''~'c _,<","y d_ ~ ',}.;~, SARA 1. WORMAN, Plaintif:C'Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW v. : NO. 01-7083 CNIL TERM JARED N. WORMAN, DefendantJRespondent : IN DNORCE PETITION FOR CONTEMPT UNDER THE PROVISIONS OF 23 Pa. C.S. DUE TO A VIOLATION OF AN ORDER OF COURT 1. The Petitioner is Sara1. Worman, the Plaintiffin the above-captioned divorce action. 2. The Respondent is Jared N. Worman, the Defendant in the above-captioned divorce action. 3. On or about December 18, 2001, the Petitioner filed an action before this Honorable Court seeking injunctive relief through a Petition for Special Relief. Petitioner filed this action because she believed that the Respondent was taking disbursements from joint marital assets without her knowledge or consent and she feared a dissipation ofthe marital estate. 4. On or about January 4, 2002, an Order was entered by this Honorable Court which provided: "AND NOW, this 4th day of January, 2002, upon consideration of Plaintiff s "Petition for Special Relief in the Form of an Injunction Presenting Removal, Disposition, Encumbering or Alienation of Property under 93505 of the Divorce Code and Pa. R.C.P. 1920.43(a)," both parties are enjoined from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property absent a written agreement between the parties and both parties shall provide to the other party an accounting of all withdrawals from any marital assets, except those which have been previously agreed to by the parties." A true and correct copy ofthis Order is attached hereto as Exhibit "A". i~,~~~.,~A;i. ,~ '"" ,. ," ",'. ,- '''._,'P'''''_'"'::""" ~'J."~-',..", ~',"'h~"'.-- ", '. .,'.~<.', '.__." , ," ~ $0"'" ,CC", ,__ . _=C"__ <.' '.~- "'".,,,-,,,,~ Z~ 5. Subsequent to the entry of this Order, the Respondent withdrew the sum of$6,000 from his IRA account, an action that was contrary to the express language of the Court's Order. 6. A hearing on the Petitioner's petition was held before this Honorable Court on May 30, 2002, at which time the Court entered an Order based upon an agreement of the parties, which is attached hereto and marked as Exhibit "B." 7. The parties were unable to agree on reimbursement for legal expenses that were incurred by the Petitioner in bringing this action. 8. Subsequent to the entry of this Order, counsel for Petitioner served upon counsel for Respondent a Request for Admissions. A true and correct copy of this document with the response of the Respondent is attached hereto as Exhibit "C." 9. In this document, the Respondent acknowledges that the Order of January 4, 2002, was entered and that he received a copy of the Order; that he withdrew the sum of $6,000 from his IRA contrary to the terms of that Order. 10. The Respondent admits that the fee agreement between Petitioner and her counsel provides for a fee of $17 5 per hour and that he has reviewed the invoice addressed to the Petitioner itemizing all charges for legal services rendered. 11. Based upon the foregoing, it is contended that there is no dispute as to the facts and that the record supports a fmding of contempt in this matter as the result of the wrongful conduct of the Respondent. -2- jt~~!Ji .~" "',' c,ty~ . ';?'\~;,>;..-;: ',_D'".;:".'"_., ;',-" " ,"' ,'I: \., -- '.N''"";'e,,,,: -"~'; ."- ". '_,;_.l' ", '~'~'1" "'_ "~~',)-'"" ~. , ~ ;""'" 12. It is contended that no further hearing in this matter is necessary and that the Court has sufficient authority under the laws of the Commonwealth of Pennsylvania and the Pennsylvania Rules of Civil Procedure. WHEREFORE, Petitioner prays that this Honorable Court fmds as follows: A.) That the actions of the Respondent in making a withdrawal from the marital IRA on or about April 15, 2002, was contrary to the provisions of the Order of January 4,2002; B.) That this action constituted an action in contempt of this Court's Order; and C.) That the Respondent shall be assessed the swn of $1,400 in legal fees payable to Kathleen Carey Daley, Esquire, within ten (10) days of the entry of the Court's Order. Respectfully submitted, DALEY LAW OFFICES By: Ka hleen Carey Daley, Es Attorney J.D. No. 30078 1029 Scenery Drive Harrisburg, PA 17109 717-657-4795 Attorney for PlaintiffiPetitioner -3- ,!,~,--t" .,.y..'.~." '-', '.~.:i;t'f.l;-,-';-,~:.~'tt~7"::,,~':,,""<' r::-;<'~'''; ~'\':.":'"f:r-"l,,,\'ffh~"_'''''~f'!!':'''-":'';;:,,~;"',,,:o.~_.,.-,",'0"",'",:" '":-,,'.,,',:,, ",;: ""~~.", ~',' """:"'",,<~>~ -,,~.~; '" , .,,""..,~"" ,,,.~-"~ ~s. VERIFICATION Upon my personal knowledge, information and belief, I, Sara 1. Worman, do hereby verifY that the facts averred and statements made in the foregoing Petition are true and correct. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. Date: By: S '~;]f~'~""~' "--."-f","c"ry.~,-',!iq?"C"~-<,'f"~:':':":"" ",o:,:'''--'''',:r.~~":.~:~!'J7~1'':'''=':~s~'''':~'-:''/,,,,,,, "~; .h'.'^"',~'T"~ """'~'''':,,', '..',._ ,~""..~." ,.~_,.,_,__" = ._..."' ".."~,.,,, ~ SARA L. WORMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JARED N. WORMAN, Defendant NO. 01-7083 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR SPECIAL RELIEF IN THE FORM OF AN INJUNCTION PREVENTING REMOVAL. DISPOSITION. ENCUMBERING OR ALIENATION OF PROPERTY UNDER ~ 3505 OF THE DIVORCE CODE AND PA.R.C.P. 1920.43(A) ORDER OF COURT AND NOW, this 4th day of January, 2002, upon consideration of Plaintiffs "Petition for Special Relief in the Form of an Injunction Preventing Removal, Disposition, Encumbering or Alienation of Property under S 3505 of the Divorce Code and Pa.R.C.P. 1920.43(a)," both parties are enjoined from disposing; transferring, encumbering, concealing, selling, rernoving, or alienating any marital property absent a written agreement between the parties and both parties shall provide to the other party an accounting of all withdrawals from any marital assets, except those which have been n previously agreed to by the parties. lI...p A hearing is scheduled for Thursday, March 14,2002, at 9:30 a.m. in Courtroom No. 1 in the Court of Common Pleas of Cumberland County in Carlisle, Pennsylvania, for purposes of considering whether this order should be continued, modified or vacated. . BY THE COURT, 1. ~ :.,,~ \; ~": Exhibit M~~ ,~'" ^' >^ '~,Jr:' .'\ .~. I' , " , ,~ '~,*< Kathleen Carey Daley, Esq. j2;l9 Scenery Drive /Harrisburg, PA 17109 Attorney for Plaintiff Jared N. Worman 86 Beacon Drive Harrisburg, PA 17II2 Pro Se Defendant Jeanne B. Costopoulos, Esq. 1400 North Second Street Harrisburg, PAl 7 102 Courtesy Copy j,i.~~ ~ ,~, , ,,~, , '1'" >. ~ _' r ' ~ 2 r, ., SARA L . WORMAN , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW JARED N. WORMAN, Defendant No. 01-7083 CIVIL TERM ORDER OF COURT AND NOW, this 30th day of May, 2002, upon consideration of the Plaintiff's "Petition for Special Relief in the Form of an Injunction Preventing Removal, Disposition, Encumbering or Alienation of property under Section 3505 of the Divorce Code and Pa. R.C.P. 1920.43(A) ," and pursuant to an agreement reached in open court in the presence of the parties and their respective counsel, Kathleen Daley, Esquire, on behalf of the Plaintiff, and Jeanne Costopoulos, Esquire, on behalf of the Defendant, it is ordered and directed as follows: 1. Both parties are enjoined from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property absent a written agreement between the parties, except for those withdrawals which have been previously agreed to by the parties. 2. Each party will furnish the other with their respective 2001 year-end IRA statements showing all withdrawals made during 2001. 3. With regard to 2002, the parties shall Exhibit "B" \~'M','W'!,i"",~~'1~'i j~ _ ~ ~ ,"" . ~ _ ". . , '. furnish each other with a copy of each monthly statement received for the IRA account as each monthly statement is received. 4. This order is entered without prejudice to Plaintiff's right to bring an action in contempt seeking additional remedies, including attorney's fees and costs, for violation of the temporary order. By the Court, J. Kathleen Daley, Esquire For the Plaintiff Jeanne B. Costopoulos, Esquire For the Defendant wcy ""j{:;;:;J;~1R ,?~ "." ,"'r...'" ~, ~, I~" ,,-' ' ,.~ ,~ " SARA 1. WORMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. JARED N. WORMAN, Defendant IN DIVORCE REOUEST FOR ADMISSIONS 1. Do you admit that the Court of Common Pleas of Cumberland County entered an Order on January 4,2002, which provided as follows: AND NOW, this 4th day of January, 2002, upon consideration of Plaintiffs "Petition for Special Relief in the Form of an Injunction Preventing Removal, Disposition, Encumbering or Alienation of Property under 93505 of the Divorce Code and Pa. R.C.P. 1920.43(a)," both parties are enjoined from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property absent a written agreement between the parties and both parties shall provide to the other party an accounting of all withdrawals from any marital assets, except those which have been previously agreed to by the partes. Answer~ 2. Do you admit that you have withdrawn the sum of $6,000 from an IRA account on or about Aprill5, 2002, contrary to the terms ofthis Order? Answer: c,/ It5. ---- Exhibit "e" ".t~~_, < ~: ~I." , , ,~ ~ I , 3. Do you admit that you had previously withdrawn sums from the account located at Raymond James under account number ID 73500402, titled as Jared N. Worman, IRA, Raymond James & Associates, Inc., that were greater than those authorized under your agreement with Sara Worman? Answer: ~~ ~ 4. Do you admit that you took the action described above without notice to or approval from Sara Worman? Answer: ~~ ~ 5. Do you admit that market conditions and withdrawals have reduced the value of the marital accounts from aDecember 31, 1998 market value of$356,828, to a December 31,2001 value of$192,093? jJ"'?J5~ 82.-8 AS I'!F Iz----?JI, q3 II ,'5tj-O--rOTAI-Wl-rfl-bUw,4/....'5 BY rrMEb Answer: '345; '~2--S I I ,q~/O'l3 -,4S of I~J?, ~ -/5?; 2..1J5" - /)\J6Z -co ~,4{lIq;T f::JEcu N FE -r tUoltJTJlLf PlflldUT5 6. Do you admit that a document identified as Exhibit "A" purports to be a true and correct copy of the fee agreement executed between Sara Worman and Daley Law Offices? Answer: !,,~~ll.$\I, ~'~"!'__'" '_ ~":""', ~ ,.,' ,,' ~ ",";," '1-- " ,~ 0 'I " - 7. Do you admit that Exhibit "A," that has been furnished to you, purports to be the bill from Daley Law Offices to Sara Worman for charges related to the Petition for Special Relief and for expected costs for the contempt action filed by the Petitioner? Answer: Yf5? ~ 8. Do you admit that you have no information in your possession that could establish that Exhibit "A" or Exhibit "B" as an erroneous or incorrect statement of the fees and costs incurred or expected to be incurred by the Petitioner in bringing the initial action seeking injunctive relief or in the action for contempt? Answer: VGS/ 9. Do you believe that you have any legal basis for the Court to find that your withdrawals which occurred in April 2002, were contrary to the express language provided by the Court's Order? Answer: l{ /3:5 : Mq f-IMIT6t:> //VCbllif (J2EhCl.c..E.t> DALEY LAW OFFICES Fvemff- B~ MY PAVIP?'- )/2- 7l-lE- f\lJ,~R1aAa[; OJ{) 52-1-.-!'P~/;JtUl-~iJS.12 \ U3A1JG.> /11/3... WITH NO '5(Juf2-c-ts ~y: OF r/Jl}A/JCtf,L f!JAc.t:-U P FO (L 44~E VNFORE5f=F-D 6-X:f'GNS~$ 5vc-N AJ. ! ) My 2i9VI F/3:t. 77+)( I~ILL. ;r.: WAb f.JD c..N-f) JCfi,. (31) T 10 ()!>E /).1 q I N V ;;'>1/0 StllT A teel UfJI , 'J'.~,. _"~. '.'~ . - . 'I ~. ~ ~-~ 1'Jllillliii11i1 ~._fi "' ~ ~"' ~ ~.". 'iJt.'" ~ ~~'-.".. ~~, ~',' ~'M ~ ~ &5- IZI/ ~ ".^~" -~,' - ..- --, - "~'U ,,-...t~ (') c.., 0 c: I~'..,) <' -n -0 IT) )> .~ n1f"ii ...- f:-~"i :7.] Z:r; G") r- 7r'- N -'"J":" tiS ;e; c...) :;)0 -<" " s.":(S ~o '''0 ... -r" ~o :x ."1:': -ri 0-- >8 ~~o 6'"11 Z c-l =<! w :P CD -< _ " ~ lFlf.If~,;,f1:>,~~ JD,gr,~:!l1'W"~m1il@li'if~~.,?,,~""I!I"0~i"" "."~"""',, "';JC,~~-. - 0 ":-"''',W' "{,,",",y,,j!~"';;i%--Wfi',j<',"W,"?~"'-"'N!",)I,!F;;"Wf!'"lifiiw"'~rm)l~;ji;c~,' SARAL. WORMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW JARED N. WORMAN, Defendant NO. 01-7083 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR CONTEMPT UNDER THE PROVISIONS OF 23 PA. C.S. DUE TO A VIOLATION OF AN ORDER OF COURT ORDER OF COURT AND NOW, this 19th day of November, 2002, due to a conflict in the Court's schedule, the hearing previously scheduled for Novernber 13, 2002, is rescheduled to Monday, January 6, 2003, at 3:15 p.m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, ./ Cara A. Boyanowski, Esq. 1029 Scenery Drive Harrisburg, PA 17109 Attorney for Plaintiff ,,/ Jearme B. Costopoulos, Esq. 1400 North Second Street Harrisburg, PA 17102 Attorney for Defendant :> t~o.jJ - jj-jq-Od-. t. \ ~S :rc :'~iI'It"" ,'"_,...",, ;''''',,~,;.c"! ,.T".'", ",' .f. c_'_.","'I"'~' ' -'-"_""11', ,~",,,'~ a~ - LlUl,~ ,L ,;~~ ,'''''''''"'.,u T __J[Jl![fg~, 'f': '.. ~, . ~,~ l~: -:,!\', ~I GLI '-1'-" ':;''1'0 ! ~ , ',:1 ,,'ll:IJII, ,:;;,lJl'l~~\1'i\'UR:~!?-#i'iW~;'iC0W-'''''''''I~-'''~';';;~4Wi~~I!lU~~~~~.m:Jjln~.-r;j;' tJJ1 . SARA L. WORMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW JARED N. WORMAN, Defendant NO. 01-7083 CIVIL TERM IN RE: PLAINTIFF'S PETITION FOR CONTEMPT UNDER THE PROVISIONS OF 23 PA. C.S. DUE TO A VIOLATION OF AN ORDER OF COURT ORDER OF COURT AND NOW, this 31st day of December, 2002, upon consideration of the attached letter from Cara A. Boyanowski, Esq., attorney for Plaintiff, the hearing previously scheduled for January 6, 2003, is cancelled. BY THE COURT, (~ t Wesley ~ara A. Boyanowski, Esq. 1029 Scenery Drive Harrisburg, PA 17109 Attorney for Plaintiff >L~ 1') RXs o I-O~-03 /learme B. Costopoulos, Esq. 1400 North Second Street Harrisburg, PA 17102 Attorney for Defendant :rc '~'!!* '. ., -" .--.-".,,'. ,,,.. ',' .~ ',~I .~.~" ^,~.~=., . "~~ ,~""""""" . ViN\-ffil!$Nt~3d ,. I I' '1"'" ", V';<"';0''''n'' i\.JJ\1 Jl_..\.! ~__.'\,I " '>':i\'~! V . 1)"'[~ "'''-) 9U :t; t!~d Z - r'~~ tiL ,\ .~,:",'," ,', ' I: I-,i:JI/Ii'.\;,II,:e,',:.," . . .....,....~r':...I)~J-i,,;~.rJ':-I, ~d -,v.J_'-- - IF' .:1'..,) .~~ " ..".__~~,~,..~141f._~ ,. < .,Q!~!f%~.m~~~""~",~1Ijt!",8,'H"r.'1'{"~"~"'f'!F;'z.!)0~I@;;\",'J:?:~]~,ZF4;;if{'f~ffii~f.WlJ<f~~M1~f . .. "" DALEY LAW OFFICES 1029 SCENERY DRIVE . HARRISBURG. PA 17109 . 1NBOX@DALEYlAWOFFlCES.COM . (717) 657-4795 . FAX (717) 657-4996 December 30, 2002 The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 Re: Worman v. Worman No. 01-7083 - Civil Term Dear Judge Oler: On August 23, 2002, our office filed a Petition for Contempt against the Defendant in the above-captioned divorce action for failure to pay this office legal fees as ordered by this Honorable Court. Subsequently, a hearing was scheduled in this matter for January 6, 2003. Please be advised that the Defendant has recently paid the required legal fees to Daley Law Offices and, therefore, the hearing scheduled for January 6, 2003, is not necessary. I respectfully request that this hearing be canceled. Thank you for your kind attention to this matter. Respectfully submitted, ~ CAB:pap cc: Jeanne B. Costopoulos, Esquire Sara 1. Worman '?l \'SiJI. \)t.C 'i!':f~_"~~,tn: L" '~', 'co ._~" ." "",' . " , 'I~ 0 , 1. {@a L, C<,N t f'YIU\.. , In the Court of Common Pleas of Cumberland County, Pennsylvania 6/-'7ow3 vs. No. Civil. ~ 2 n 0;) ::Tar.u( N. WiJ/'I'M/L JJ'V~fI:-e- 76 ~ ~J\ d~4ar.; : rfp~ ~ #l-t; 1rOcbrtLuu.L dYt idta1( Y J1.J.. I~J YtfAd/) N. WtfUr\d"". < :kU.If/\/ C<s*frTtA.-LU 1<{l'o N 2 /LJ- Srll lifJ fU- n I~.J To Prothonotary 19 nlv'N- 717 aIr I o,,/oa S-- oJ..- Xo 6f!7SS' ;Z- ~,U1 ". W' . 'Nr ~<-R?^J, "~".4!ll1!'''',. '__' ~~ j I' " ,~. ...............,- ~~~, ~'.....""_. '0' , ~ ,~ ~....""""" nt." "" ,,", ,~"~ = ~,~ -. ,. . .~~,<, ,~_,_o'" '~~I"- ~ ~ - '~"""""'~':{~ No. Term, 19 _ vs. PRAECIPE Filed 19 Atty. \-/ij\J"ilY'lAS~'JNjd AJJ'ff.r:! '. ;.'1':!~2V\Jn~) 9 U :(~ i'.~J 0 E )..'~,;H (,v At\fl.l/:_, , -1"".1' I"" C-"'" I :J,JLJ.:a..r '::: Ii:: :!() f-~ ~:!'m!",!,Jmr,M-~ ",. <?',,~ f:~~~l~,1\~~,'i}~~f'-f~~'Ijfi~fJli;Al'1%-~1-'<'ffi1<:''''''''-''''':ltffi~~I\(~"1f!J1!lf.~,!!iiill}~,.:~m~',-*,y~f'\~.:rp,~~hi,%,::,~,jf,,,3h ""-\~,~"~""-'41j;:(~~;I,:~j~7.liift!l'~rfff~\~~'!tii!~-tj~~~1J