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ELLIOT DETWILER, JR.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff'
CIVIL ACTION - LAW
VS. NO. 99-2261 CIVIL 19
MONA L. DETWILER IN DIVORCE
Defendant
STATUS SHEET
DATE- I? ACTIVITIES:
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ELLIOT DETWILER, JR.
Plaintiff
VS.
MONA L. DETWILER,
Defendant
TO: James J. Kayer
Lee E. Osterling
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 2261 CIVIL
IN DIVORCE
Attorney for Plaintiff
Attorney for Defendant
DATE: Friday, February 23, 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE COUNSEL FOR PLAINTIFF ( )
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240.6535
E. Robert Elicker, II
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
Lee E. Oesterling, Esquire
HAZLETT ft OESTERLING
20 South Market Street
Mechanicsburg, PA 17055
RE: Elliott Detwiler, Jr
No. 99 - 2261 Civil
In Divorce
October 19, 2001
Mona L. Detwiler
339 Shed Road
Newville, PA 17241
vs. Mona L. Detwiler
Dear Mr. Oesterling and Ms. Detwiler:
West Shore
697.0371 Ext. 6535
It appears by the file that Mr. Kayer has been replaced by Mr. Oesterling
as counsel for Plaintiff and that Ms. Detwiler has not retained counsel to
represent her. I have a certification document from Mr. Kayer and Mr.
Oesterling indicating that discovery is complete; I have not heard from Ms.
Detwiler or counsel on her behalf.
I am going to proceed on the basis that grounds for divorce are not an
issue and that there are no outstanding discovery matters to be resolved.
This action was originally commenced in Cameron County and then
transferred to Cumberland County. The economic claim raised in the
supplemental complaint is equitable distribution. No claims have been raised
for alimony or counsel fees and costs although the motion for appointment of
Master indicates that those matters are at issue. Unless an amended
complaint, counterclaim or petition is filed raising those claims, they will not
be considered in my review of the case.
In accordance with P.R.C.P. 1920.33(b) I am directing Mr.
Oesterling and Ms. Detwiler to each file a pretrial statement on or before
Friday, November 16, 2001. Upon receipt of the pretrial statements, I will
immediately schedule a pre-hearing conference with counsel and Ms. Detwiler,
Mr. Oesterling and Ms. Detwiler
19 October 2001
Page 2
if she remains unrepresented, to discuss the issues and, if necessary, schedule
a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
yy-d-, (,p I &-?.
IN THE COURT OF COMMON PLEAS OF CAMERON COUNTY
Fifty - Ninth Judicial District
NO: 98- 5066 DEBT: $ 0.00
RECORDED: 08/24/98 SURCHARGE: 10.00
BOOK: PAGE: 0 PRO: 30.50
KIND: DIV JCP FEE: 5.00
SAT DATE: 03/05/99
<PLAINTIFF> 1 DETWILER ELLIOTT JR
<DEFENDANT> 1 DETWILER MONA L
AUGUST 24, 1998 - Plaintiff's Complaint in Divorce filed by LEE E.
OESTERLING, ESQ.
SAME DATE: Certified copy of Complaint with endorsement thereon to plead to
same, issued for service upon the defendant.
Verification filed:
SEPTEMBER 28, 1998 - Affidavit of Service by Certified Mail and certified
card filed:
MARCH 5, 1999 - Motion to Transfer Divorce Complaint w/Stipulation filed on
behalf of Plaintiff by LEE E. OESTERLING, ESQ. ($39.00 Fee Paid)
MARCH 9, 1999 - ORDER OF COURT FILED:
AND NOW, on this 5th day of March, 1999 it is ORDERED AND DECREED that
the aforementioned Complaint for Divorce, docket number 98-5066 and all
documentation related thereto, shall be transferrred to Cumberland County,
Pennsylvania pursuant to and in conformity with the enclosed Motion to
Transfer.
BY THE COURT: /s/Vernon D. Roof, P.J.
copies to Atty.Oesterling and Atty.Kayer. bgm
True and Correct Copy
certified from the
Records of Cameron Co-
Penna.
Prothonotary
IN THE COURT OF COMMON PLEAS OF
CAMERON COUNTY, PENNSYLVANIA
ELLIOTT DETWILER, JR.
Plaintiff,
No. ?T'_SbGI?
V.
MONA J. DETWILER
Defendant
Civil Action - Divorce
NOTICE TO DEFEND AND CLAIM OF RIGHTS
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YOU HAVE BEEN SUED IN COURT. If you wish to defend against tho 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 requcited in these papers by
the Plaintiff. You may lose money or property or other rights important to yo.6 including custody or
visitation ofyour children.
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 ONCI.. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Office of The Prothonotary
East 5a' Street
Emporium, Pennsylvania 15834
Telephone: (814) 486-3349
e i Correct Copy
liri-,J from the
:c nx> of Cameron Co.
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NOTICE OF AVAILABILITY OF COUNSELING =•
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THE DIVORCE CODE OF PENNSYLVANIA REQUIRES THAT YOU BE NOT
OF THE AVAILABILITY OF COUNSELING WHERE A DIVORCE IS SOUGHT UNDER ANY
OF THE FOLLOWING GROUNDS:
23 Pa.C.S. § 3301(a)(6) - Indignities
23 Pa.C.S. § 3301(c) - Irretrievable Breakdown; Mutual Consent
23 Pa.C.S. § 3301(d) - Irretrievable Breakdown; Two year separation where the court
determines that there is a reasonable prospect of reconciliation
A list of marriage counselors is available in the Office of the Prothonotary, Cameron County
Courthouse, East 5'" Street, Emporium, Pennsylvania 15834. Telephone: (814) 486-3349.
HAZLETT & OESTERLING
Lee E. Oesterling, I.D. # 7
Attorney for Plaintiff
22 South Market Street
Mechanicsburg, PA 17055
(717790-04True an COPY
certified from ,the
Records of Cameron CO.
Penna.
IN THE COURT OF COMMON PLEAS OF
CAMERON COUNTY, PENNSYLVANIA ° `? T
ELLIOTT DETWILER,JIL
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No. q?-? 06 L I? a S=am
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Civil Action - Divorce `? rv c
MONA L DETWILER 00 Yo
Defendant
COMPLAINT UNDER SECITON
3301(c) OR 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Elliott Detwiler, Jr., an adult individual, sui juris, who currently resides at, 151
Pine Hill Road, City of Carlisle, County of Cumberland, Commonwealth of Pennsylvania
17013.
2. Defendant is Mona L. Detwiler, an adult individual, sui juris who currently resides at, 339
Shed Road, City of Newville, County of Cumberland, Commonwealth of Pennsylvania,
17241.
3. Plaintiff has been a bona fide resident of the Commonwealth of Penmylvania for a period
of more than six (6) months immediately preceding the filing of this complaint.
4. The parties were married on the 16th day of August, 1962, in the State of Maryland.
5. Neither Plaintiff nor Defendant is in the military or naval service of tie United States or its
allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of
1940 and its amendments.
True and Correct Copy
certified from the
Records of Cameron Co.
Penna.
Prothonotary
6. There have been no prior actions for divorce or annulment instituted by either of the parties
in this or any other jurisdiction. ' C'03 t7
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7. For purposes of § 3301(d) of the Divorce Code
the parties have be
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8. The marriage is irretrievably broken.; T
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9. Plaintiff has been advised that counseling is available and that Plaintitl may have the
right to request that the court require the parties to participate in counseling.
10. After ninety (90) days have elapsed from the date of the filing of thi, Complaint,
Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff bolieves that
Defendant may also file such an affidavit.
11. The parties have not entered into a written agreement as to support, alimony or property
division, but reserve the right to do so prior to or contemporaneous]% with the entry of a
Decree in Divorce.
12. There are no minor children of the marriage.
True and Correct Copy
certified from the
!Records of Cameron Co.
'anna.
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COUNT I j ? r7
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REQUEST FOR A NO-FAULT DIVORCE UNDER § 3301(c) OF THE. D ,
RCE 4M DE 0
13. The prior paragraphs of this Complaint are incorporated herein by;,;f a eetltereta C
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14. The marriage of the parties is irretrievably broken. - z
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WHEREFORE, if both parties file affidavits consenting to a divorce after (90) days have
elapsed from the date of the filing of this Complaint, plaintiff respectfully reque,ts the Court to enter a
decree of divorce pursuant to § 3301(c) of the Divorce Code.
HAZI & OESTERLING
Lee E. Oesterl-mg, I.D. # 7
Attorney for Plaintiff
22 South Market Street
Mechanicsburg, PA 17055
(717)790-0490
Date:
True and Correct Copy
certified from the
Records of Cameron Co.
Penna.
Prothonotary
VERIFICATION
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I verify that upon personal knowledge or information and belief that the statements made in this
Complaint are true and correct. I understand that Use statements herein arc made sub;ect to the penalties of 18
Pa.C.S. § 4904, relating to unworn falsification to authorities.
Date: 3
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True and Correct Copy.
certified from the
Records of Cameron Co.
Penna. _
Prothonotarlr
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CAMERON COUNTY, PENNSYLVANIA
ELLIOTT DETWILER, JR.
Plaintiff,
No. 98-5066
V.
Civil Action - Divorce
MONA L. DETWILER LID r
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Defendant
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AFFIDAVIT OF SERVICE BY CERTIFIED MAIL i i 1`
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Lee E. Oesterling, Esquire, attorney for Plaintiff in the above-captioned Divorce,
deposes and says that he mailed a copy of the Complaint in Divorce filed in this matter by
certified mail, return receipt requested, and first class mail to the Defendant, Mona L.
Detwiler at 339 Shed Road, Newville, PA 17241 on September 10, 1998. Deponent
further says that the certified mail N P405056832 was received on 9-19-98 and that the
first class mail was not returned and has not been returned as of the date of this affidavit.
and correct copy of the return receipt is attached hereto as Exhibit "A".
Lee E. Oesterling, Esquire
22 South Market Street
Mechanicsburg, PA 17055
(717)790.0490
Attorney for Plaintiff
True and Correct Copy
certified from the
Records of Cameron Co.
Penna.
Prothonotary
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3. Article Addressed to:
MONA L. DETWILER
339 SHED ROAD
NEWVILLE, PA 17241
5R ed By: (Pant )
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LEE E. OESTERLING, ESQUIRE
22 SOUTH MARKET STREET
MECHANICSBURG, PA 17055
True and Correct Copy
certified from the
Records of Cameron Co.
Penna.
I also wish to reoelva the
following services (for an
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2. ? Restricted Dallwry
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Prothonotary
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IN THE COURT OF COMMON PLEAS OF
CAMERON COUNTY PENNSYLVANIA
ELLIOTT DETWILER, JR.
Plaintiff,
Docket No. 98-5066 7- v3
V. LLJ
Civil Action - Divorce '=
MONA L. DETWILER
Defendant cat
MOTION TO TRANSFER DIVORCE COMPLAINT '
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1.
99 Mainsville Road, City of Shippensburg, County of Franklin, Commonwealth of
Pennsylvania 17257-1746.
2. Defendant to this action is Mona L. Detwiler, whose last known address is 339 Shed Road,
City of Newville, County of Cumberland, Commonwealth of Pennsylvania, 17241.
3. Plaintiff filed a Complaint for divorce with Court of Common Pleas, of Cameron
County at docket number 98-5066 requesting a Divorce under § 3301 (c) of the
Divorce Code.
4. Plaintiff and Defendant, have entered into a stipulation to transfer venue if the
matter should require the intervention of the court on various issues surrounding
dissolution of the marriage. A true and correct copy of said stipulation is attached hereto
as Exhibit "A."
5. The matter has become contested as to distribution of marital assets and obligations
between the parties.
WHEREFORE, Plaintiff prays that this Honorable Court transfer the complaint
for divorce and all supporting documentation to Cumberland County, Pennsylvania.
Dated: 3 /1/99
Lee E. Oesterling, Esquire, #71320
Attorney for Plaintiff True and Correct Copy
22 South Market Street certified from the
Mechanicsburg, PA 17055 Records of Cameron Co.
Penna.
Prothonotary Oi?l???
IN THE COURT OF COMMON PLEAS OF
CAMERON COUNTY, PENNSYLVANIA
ELLIOTT DETWILER. JR.,
Plaintiff
V.
MONA L. DETWILER.
Defendant
No. 9&5066
Civil Action - Divorce
STIPULATION
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COMES NOW, James J. Kayer, Esquire, representing the Defendant, Mona Detweiler
and Lee Osterling, Esquire, representing, Plaintiff, Elliott Detweiler. Jr., who do stipulate as
follows:
1. That the parties shall exchange pertinent information concerning economic issues
incident to the divorce. These inquiries may be through either formal discovery including
interrogatories or informal discovery through an exchange of correspondence.
2. The Defendant does not waive her right to object to the venue of this divorce
reaching this Stipulation or responding to the discovery requests of the Plaintiff.
3. Plaintiff agrees that in the event that any issue incident to the divorce including but
not limited to equitable distribution, alimony pendente lite, spousal support, alimony, or award
of counsel fees and costs, becomes contested between the parties, that this matter shall be
transferred to the court that has appropriate venue in this [natter, the Cumberland County
Court of Common Pleas and that the Plaintiff shall be responsible solely for any expenses
se to Cumberland County Court of Common Pleas.
James J. Kayer, Esquire True and Correct Copy
certified from the
Records of Cameron Co.
Penna.
Date
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/z-3-Y115-
Date
77
IN THE COURT OF COMMON PLEAS OF 1O ? %=
CAMERON COUNTY PENNSYLVANIA x ii n
ELLIOTT DETWILER, JR.
Plaintiff, _
Docket No. 98-5066 00
V. r
Civil Action - Divorce
MONA L. DETWILER
Defendant
ORDER
AND NOW, on this 6-rM day of M ARC N 1999 it is ORDERED AND
DECREED that the aforementioned Complaint for Divorce, docket number 98-5066 and
all documentation related thereto, shall be transferred to Cumberland
County, Pennsylvania pursuant to and in conformity with the enclosed Motion to
Transfer.
FOR TI fPVRT:
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correct COPY
certified from the
Records of Cameron Co.
Penna.
Prothonotary
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Hazlett & Oesterling
ATTORNEYS AND COUNSELORS AT LAW
20 SOUTH MARKET STREET
MECHANICSBURG. PA 17066
Phona(717)790.0490
Fax(717)790.9279
GREGORY S. HAZLETT, ESQ. LEE E. OESTERLING, ESQ.
October 18, 2001
Office of The Divorce Master
E. Robert Ellicker, II
Carlisle, PA 17013
RE: Detwiler v. Detwiler / 99.2261- In Divorce
Dear Mr. Elicker,
Please accept this letter as my confirmation that discovery is complete in the
above referenced matter. Please contact my office in regard to available dates for
the initial conference.
APR 1 9199 jam)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
ELLIOTT DETWILER, JR.
Plaintiff,
Casc No.-!n6( e?
V.
MONA L. DETWILER
Defendant
Civil Action - Divorce
ORDER
AND NOW, this ?0 ay of
19 (, in consideration of plaintiffs
Motion to Amend Divorce Complaint, it is hereby Ordered and Decreed that such Motio
is hereby gra d '? P ?'"'^1 a-+4 ? .t?f. .:.? ct--
42 CA l9av. 13
By the C
J.
FILEfN?f i fCc?Tl1?Y
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99 '? 2 I t;ii 9: 30
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
ELLIOTT DETWILER, JR.
Plaintiff,
Case No. 9q- J..Z (-t 6?j 7-e-
V.
MONA L. DETWILER
Defendant
Civil Action - Divorce
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
Plaintiff, Elliott Detwiler, Jr, by his attorney Lee E. Oesterling, Esquire, respectfully represents
and moves this court as follows:
1. A Complaint in Divorce was filed to the above term and number on
in Cumberland County Pennsylvania.
2. The Complaint, as filed, does not address the respective property rights as they now exist
between the parties and plaintiff seeks to amend to add a count for equitable distribution.
3. Plaintiff's counsel has sought the concurrence of defendant's counsel to which there is / is
not concurrence with the relief requested herein.
4. Plaintiff therefore seeks to add the following count to his complaint and alleges as follows:
COUNT II
PETITION FOR EQUITABLE DIVISION, DISTRIBUTION AND ASSIGNMENT OF
MARITAL PROPERTY
15. The averments of paragraph 1 through 15 of Count I are incorporated herein
by direct references thereto as if set forth verbatim.
16. The parties are the owners of various items of personal property and real property
which has been acquired during marriage which qualifies as marital property as defined in
Section 401 of the 1980 Divorce Code.
17. Such marital property includes both real and personal property as well as other
intangible property thought to exist, including but not by way of limitation bank
accounts, pensions and other property not capable of being listed herein.
18. Such property is subject to equitable division, distribution and assignment by this
Court fundamental to the rights and responsibilities of the parties to the divorce
Complaint.
WHEREFORE, Plaintiff prays that this Honorable Court:
(a) equitably divide, distribute and assign all of the parties' marital property:
(b) enjoin Defendant from transferring or encumbering any marital property
during the pendency of this action.
Lee E. Oesste ing%Esquire
20 South Market Street
Mechanicsburg, PA 17055
(717) 790-0490
I verify that upon personal knowledge or information and belief 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. & 4904, relating to unswom falsification
to authorities
Date: E wo Jll Y
Plaintiff
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Kayer and Brown
Attorneys At Law
A Professional Corporation
Liberty Loft
4 E. Liberty Avenue
Carlisle, Pennsylvania 17013
e-mail: Ikayer®eplx. n et
Telephone: (717) 243.7922
Office of Divorce Master
E. Robert Elicker, II
9 North Hanover
Carlisle PA 17013
February 27, 2001
RE: Detwiler vs. Detwiler - In Divorce
Dear Mr. Elicker:
FAX: (717) 243.0946
Please find enclosed the Certification for Discovery that I have completed on behalf of
my client, Mona Detwiler.
Thank you for your attention to this matter.
JJK/vjg
cc: Mona Detwiler
Lee Osterling, Esq.
Very truly yours,
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ELLIOTT DETWILER, JR.,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 2261 CIVIL TERM
MONA L. DETWILER,
Defendant
claims.
: IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
Mona L. Detwiler, Defendant, moves the court to appoint a master with respect to the following
(X) Divorce (X) Distribution of Property
( ) Annulment ( ) Support
(X) Alimony (X) Counsel Fees
( ) Alimony Pendente Lite
(X) Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claim(s) for which the appointment of a master is requested.
(2) The plaintiff has appeared in the action, and is represented by Lee Osterling, Esq.
(3) The statutory grounds for divorce is 3301(d).
(4) Delete the inapplicable paragraph(s):
(a) The action is contested with respect to the following claims: Distribution of property
Attorneys Fees and Costs
Alimony
(5) The action does not involve complex issues of law or fact.
(6) The hearing is expected to take six to eight (6 to 8) hours.
(7) Additional information, if any, relevant to the motion: None.
Date: February 8, 2001
4
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AND NOW
following claims: _
Plaintiff
ORDER APPOINTING MASTER
Esquire, is appointed master with respect to the
BY TH:
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its F'I cC?Crs File
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CERTIFICATE OF SERVICE
1 hereby certify that a true copy of the foregoing Appointment for Master was served on the
following person by First-class mail, postage prepaid addressed to:
Lee Osterling
Hazlett & Osterling
22 South Market Street
Mechanicsburg PA 17055
Date: A/14 /o/
(717) 243-7922
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ELLIOT DETWILER, JR.
Plaintiff
VS.
MONA L. DETWILER,
Defendant
TO: James J. Kayer
Lee E. Osterling
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 2261 CIVIL
IN DIVORCE
Attorney for Plaintiff
Attorney for Defendant
DATE: Friday, February 23, 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
-z-
lz"4 /?-- /I DATE OUNS
"0 fINTIF? F- ( )
COUNSEL FO D FENDANT (1.)
NOTE: PRETRIAL DIRECTIVES WILLM*OT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
FEB 2 6 2001 ' 1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ELLIOTT DETWILER, JR.
Plaintiff,
No. 99-2261
V.
MONA L. DETWILER
Defendant
Civil Action - Divorce
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in
the following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by the
Court. A judgment may also be entered against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other rights important to you, including
custody or visitation of your children.
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 Co. Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ELLIOTT DETWILER, JR.
Plaintiff,
V.
No. 99-2261
Civil Action - Divorce
MONA L. DETWILER
Defendant
AND NOW, Plaintiff, Elliott Detwiler, Jr. in accordance with Pa.R.C.P. 1920.13, by and through
his attorney Lee Eric Oesterling, Esquire, after having duly paid the filing fee and amendment fee,
amends as a matter of course the complaint in divorce docketed at the above captioned civil action
to include the following:
COUNT IT
PETITION FOR EQUITABLE DIVISION, DISTRIBUTION AND ASSIGNMENT OF MARITAL
PROPERTY
15. The prior paragraphs of the Complaint docketed at 99-2261 Civil Term, numbered I through 14 are
incorporated by reference as if fully set forth herein.
16. The parties are the owners of various items of personal property and real property
which has been acquired during marriage which qualifies as marital property as defined in
Section 401 of the 1980 Divorce Code.
17. Such marital property includes real and personal property as well as other
intangible property thought to exist, including but not by way of limitation bank
accounts, pensions and other property not capable of being listed herein.
18. Such property is subject to equitable division, distribution and assignment by this
Court.
4
WHEREFORE, Plaintiff prays that this Honorable Court:
(a) equitably divide, distribute and assign all of the parties' marital property:
(b) enjoin Defendant from transferring or encumbering any marital property
during the pendency of this action.
U!/'?/.IUIU/GG
Lee E. Oesterling, Esquire
Supreme Court I.D. # 71320
20 South Market Street
Mechanicsburg, PA 17055
(717) 790-0490
I verify that upon personal knowledge or information and belief 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. & 4904, relating to unsworn falsification
to authorities
Date--243o r
k ntiff
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O C?+ V
ELLIOT DETWILER, JR. IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 99 - 2261 CIVIL
MONA L. DETWILER,
Defendant IN DIVORCE
TO: James J. Kayer , Attorney for Plaintiff
Lee E. Osterling , Attorney for Defendant
DATE: Friday, February 23, 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
101-Al,(171 c
4)BPNDMT MUST COMPLETE IF1?( J APPRAISEMENT
HAVE NOT RECEIVED FROM COUNSEL ANY COPIES
OF PLAINTIFF'S INVENTORY AND APRRAISMENT.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
SCHEDULES SENT TO BBPSNBPAFP, AND REQUEST MADE FOR
SAME FROM ATTORNEY FOR PLAINW!
b E/4EN,0NNY
DISCOVERY TO BE COMPLETED BY MAY 30, 2001
DATE COUNS P NTIFF
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRE TI:VE WILL NOT BE ISSUED FOR THE
FILING OF PR TRITATEM ENTS UNTIL COUNSEL HAVE
CERTIFIED T T DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
i'a eau
I I.
PETER J. RUSSO, ESQUIRE Attorney for Defendant
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
ELLIOT DETWILER, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-2261 CIVIL TERM
MONA L. DETWILER, : CIVIL ACTION - LAW
Defendant : DIVORCE
ENTRY OF APPEARANCE OF COUNSEL
Kindly enter my appearance on behalf of Mona L. Detwiler, Defendant in the
above matter.
Peter J. Russo
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
Datod: 1 o l a- l o t
PETER J. RUSSO, ESQUIRE Attorney for Defendant
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
ELLIOT DETWILER, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-2261 CIVIL TERM
MONA L. DETWILER, : CIVIL ACTION - LAW
Defendant : DIVORCE
CERTIFICATE OF SERVICE
I, Peter J. Russo, hereby certify that I am on this day serving a copy of the
ENTRY OF APPEARANCE
upon the person (s) and in the manner indicated below, service by First-Class Mail,
Postage Prepaid, and Addressed as Follows:
Lee E. Oesteding, Esq.
22 South Market Street
Mechanicsburg, PA 17050
c-
Peter J. Russo
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
Date: jujagjo%
PETER J. RUSSO, ESQUIRE
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
ELLIOT DETWILER, JR.,
Plaintiff
V.
MONA L. DETWILER,
Defendant
Attorney for Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-2261 CIVIL TERM
CIVIL ACTION - LAW
DIVORCE
ENTRY OF APPEARANCE OF COUNSEL
Kindly enter my appearance on behalf of Mona L. Detwiler, Defendant in the
above matter.
Peter J. Russo
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
Dated: _1oja,loN
j 46
Attorney for Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-2261 CIVIL TERM
: CIVIL ACTION - LAW
: DIVORCE
CERTIFICATE OF SERVICE
I, Peter J. Russo, hereby certify that I am on this day serving a copy of the
ENTRY OF APPEARANCE
Lee E. Oesterling, Esq.
22 South Market Street
Mechanicsburg, PA 17050
Peter J. Russo
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717)591-1755
PETER J. RUSSO, ESQUIRE
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
ELLIOT DETWILER, JR.,
Plaintiff
V.
MONA L. DETWILER,
Defendant
upon the person (s) and in the manner indicated below, service by First-Class Mail,
Postage Prepaid, and Addressed as Follows:
Date: ?olag10%
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ELLIOT DETWILER, JR.,
Plaintiff
V.
MONA L. DETWILER,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 99-2261 CIVIL
Defendant C2 m ,-;
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PRE-TRIAL STATEMENT PURSUANT TO RULE 1920.33 v ? a,
I. HISTORY ice, -t
The Plaintiff, Elliot Detwiler, Jr., and the Defendant, Mona L. Detwiler, were`
married on August 16, 1961. The parties entered into a Separation Agreement on May
18, 1998. Defendant first filed for divorce on August 24, 1998 in Cameron County. The
parties later reconciled for a period, but the divorce action was then renewed. On
March 5, 1999, the action was transferred to Cumberland County. Upon Defendant's
motion, a master was appointed on February 14, 2001.
The Plaintiff, Elliot Detwiler, Jr., is 57 years old and is employed by Autohaus
Harrisburg. The Defendant, Mona L. Detwiler, is also 57 years old and is employed by
RDS of Richmond, Virginia.
Ii. LIST OF MARITAL ASSETS - REAL ESTATE
Asset Asset Mar. Portion Liens
Land located at 339 $27,000 100% N/A
Shed Road, Newville.
Mobile home on the N/A 0% N/A
land.
111. ACCOUNTS AND INTANGIBLE PERSONAL PROPERTY
Asset Value Mar. Portion
Plaintiffs Sun $8,400 100%
America IRA
Defendant's Sun $2,000 100%
America IRA
Washington National $5,400 100%
Life Insurance Policy
IV. TANGIBLE PERSONAL PROPERTY
The parties have agreed that each party will retain his own vehicle and all other
personal property.
V. EMPLOYMENT AND INCOME
Mr. Detwiler is employed by Autohaus Harrisburg. Mrs. Detwiler is employed by
RDS of Richmond, Virginia. A support order exists from February 5, 1999.
VI. WITNESSES
Defendant will testify on her own behalf regarding the marital property and her
Income and expenses.
VII. EVIDENCE AND EXHIBITS
The list of exhibits is as follows:
A. Property Appraisal dated 12/1/1997.
B. SunAmerica Statements dated 4/1/1998.
C. Cumberland County Domestic Relations Order dated 2/5/1999.
VIII. TANGIBLE PERSONAL PROPERTY
The parties will remain co-owners of the Washington National Life Insurance Policy.
They will split the combined total of the land and their IRA accounts equally. Mrs. Detwiler
will retain the land and will pay Mr. Detwiler his share of $13,500.00 over the next 36
months at a rate of $291.66 per month. This payment amount factors in Mrs. Detwilers
$3,000.00 share of the IRA account totals.
Mr. Detwiler will continue to pay Mrs. Detwiler's health insurance coverage. The
Cumberland County Domestic Relations support order from February 5, 1999 will remain in
effect until such time as Mrs. Detwiler remarries, cohabitates or dies.
Date: 1111001
Respectfully submitted,
Peter J. Russo, Esquire
Attorney ID 72897
5010 E. Trindle Road
Suite 200
Mechanicsburg, PA 17050
PETER J. RUSSO, ESQUIRE Attorney for Defendant
5010 E. Tdndle Road
Mechanicsburg, PA 17050
(717) 591-1755
ELLIOT DETWILER, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99.2261 CIVIL TERM
MONA L. DETWILER, : CIVIL ACTION - LAW
Defendant : DIVORCE
CERTIFICATE OF SERVICE
I, Peter J. Russo, hereby certify that I am on this day serving a copy of the
PRE-TRIAL STATEMENT PURSUANT TO RULE 1920.33
upon the person (s) and in the manner indicated below, service by First-Class Mail,
Postage Prepaid, and Addressed as Follows:
Lee E. Oesterling, Esq.
22 South Market Street
Mechanicsburg, PA 17050
C?&a
Peter J. Russo
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
Date: 11111010%
ELLIOT DETWILER, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
MONA L. DETWILER, No. 99.2261 CIVIL
Defendant
PRE-TRIAL STATEMENT PURSUANT TO RULE 1920.33
1. HISTORY
The Plaintiff, Elliot Detwiler, Jr., and the Defendant, Mona L. Detwiler, were
married on August 16, 1961. The parties entered into a Separation Agreement on May
18, 1998. Defendant first filed for divorce on August 24, 1998 in Cameron County. The
parties later reconciled for a period, but the divorce action was then renewed. On
March 5, 1999, the action was transferred to Cumberland County. Upon Defendant's
motion, a master was appointed on February 14, 2001.
The Plaintiff, Elliot Detwiler, Jr., is 57 years old and is employed by Autohaus
Harrisburg. The Defendant, Mona L. Detwiler, is also 57 years old and is employed by
RDS of Richmond, Virginia.
if. LIST OF MARITAL ASSETS - REAL ESTATE
Asset Asset Mar. Portion Liens
Land located at 339 $27,000 100% N/A
Shed Road, Newville.
Mobile home on the N/A 0% N/A
land.
III. ACCOUNTS AND INTANGIBLE PERSONAL PROPERTY
Asset Value Mar. Portion
Plaintiffs Sun $8,400 100%
America IRA
Defendant's Sun $2,000 100%
America IRA
Washington National $5,400 100%
Life Insurance Policy
a.• -
IV. TANGIBLE PERSONAL PROPERTY
The parties have agreed that each party will retain his own vehicle and all other
personal property.
V. EMPLOYMENT AND INCOME
Mr. Detwiler is employed by Autohaus Harrisburg. Mrs. Detwiler is employed by
RDS of Richmond, Virginia. A support order exists from February 5, 1999.
VI. WITNESSES
Defendant will testify on her own behalf regarding the marital property and her
income and expenses.
VII. EVIDENCE AND EXHIBITS
The list of exhibits is as follows:
A. Property Appraisal dated 12/1/1997.
B. SunAmerica Statements dated 4/1/1998.
C. Cumberland County Domestic Relations Order dated 2/5/1999.
VIII. TANGIBLE PERSONAL PROPERTY
The parties will remain co-owners of the Washington National Life Insurance Policy.
They will split the combined total of the land and their IRA accounts equally. Mrs. Detwiler
will retain the land and will pay Mr. Detwiler his share of $13,500.00 over the next 36
months at a rate of $291.66 per month. This payment amount factors in Mrs. Detwiler's
$3,000.00 share of the IRA account totals.
Mr. Detwiler will continue to pay Mrs. Detwiler's health insurance coverage. The
Cumberland County Domestic Relations support order from February 5, 1999 will remain in
effect until such time as Mrs. Detwiler remarries, cohabitates or dies.
Respectfully submitted,
Date: 9 1111.101
Peter J. Russo, Esquire
Attorney ID 72897
5010 E. Trindle Road
Suite 200
Mechanicsburg, PA 17050
PETER J. RUSSO, ESQUIRE
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
ELLIOT DETWILER, JR.,
Plaintiff
V.
MONA L. DETWILER,
Defendant
Attorney for Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-2261 CIVIL TERM
: CIVIL ACTION -LAW
: DIVORCE
CERTIFICATE OF SERVICE
I, Peter J. Russo, hereby certify that I am on this day serving a copy of the
PRE-TRIAL STATEMENT PURSUANT TO RULE 1920.33
upon the person (s) and in the manner indicated below, service by First-Class Mail,
Postage Prepaid, and Addressed as Follows:
Lee E. Oesterling, Esq.
22 South Market Street
Mechanicsburg, PA 17050
Peter J. Russo
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
Date: 11 111 10%
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' 'a to
ELLIOT DETWILER, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 99 - 2261 CIVIL
MONA L. DETWILER,
Defendant IN DIVORCE
AND NOW, this Sad day of t!c
2002, the economic claims raised in the proceedings having
been resolved in accordance with a stipulated alimony
agreement and equitable distribution dated December 15,
2001, the appointment of the Master is vacated and counsel
can file a praecipe transmitting the record to the Court
requesting a final decree in divorce.
BY THE COURT,
Ge AgE. o fer, P J.
cc: Lee E. Oesterling
Attorney for Plaintiff
Peter J. Russo
Attorney for Defendant
''Y
r'.
02 JJAN, °? Ai'i 10: 1114
PENNSYLVAN A
•o
ELLIOT DETWILER, JR.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
MONA L. DEWILER NO. 99-2261 CIVIL TERM
Defendant IN DIVORCE
STIPULATED ALIMONY AGREEMENT
AND EQUITABLE DISTRIBUTION
This Agreement is hereby made and entered into this _-i-V3ay of , ?ff
. ?2p01
by and between MONA L. DEWILER, "Wife," and ELLIOT DETWLLER, JR., hereinafter
"Husband."
Witnesseth:
Whereas, the Parties hereto are husband and wife; and
Whereas, marital differences and difficulties have arisen between the Parties; and
Whereas, Parties have separated physically and intended to continue to live apart and
desire to forever completely settle, separation of their marital and nonmarital, real and personal,
belonging to either and/or both of the parties hereto and all other rights, entitlements, benefits, and
privileges involved between the parties hereto arising directly or indirectly out of the marriage
relationship; and
Whereas, Parties have had adequate time and opportunity to consult with separate legal
counsel of their own; and
Whereas, both Parties acknowledge that they are satisfied with the legal advice they have
received and understand the full importance of the Agreement they are entering into; and
Q':'/ `ED Page 1 of 14
MLD
Now, Therefore, the parties, in consideration of the foregoing premises, and the mutual
promises and undertakings hereinafter set forth, agree as follows:
1. RIGHT TO LIVE EPARATE
It shall be lawful for Husband and Wife at all times hereinafter to live separate and apart
from each other and to reside from time to time at such place or places as he and she shall
respectively deem fit, free from any control, restraint or interference, direct or indirect, by each
other. The foregoing provisions shall not be taken to be any admission on the part of either
Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living apart.
2. FREEDOM FROM INTERFERENCE
Each party shall be free from interference, authority and contact by the other as if he or she
were single and unmarried except as necessary to carry out provisions of this Agreement. Neither
party shall harass the other or attempt to endeavor to harass the other, nor compel the other to
cohabit with the other, or in any way malign the other, nor in any way interfere with the peaceful
existence, separate and apart from the other.
3. DISTRIBUTION AND RELEASE OF MARITAL DEBT
The parties agree:
a. Wife assumes full responsibility for any indebtedness which she has
contracted or incurred in her name, alone or jointly, after the date of separation. Wife represents
and warrants to Husband that, since the date of separation, she has not contracted or incurred any
debt or liability, for which Husband or his Estate might be responsible, and shall indemnify and
save Husband harmless from any and all claims or demands made against his or his Estate by
reason of debts or obligations incurred by Wife and/or assumed herein.
ED Page 2 of 14
MLD
b. Husband assumes full responsibility for any indebtedness which he has
contracted or incurred in his name, alone or jointly, after the date of separation. Husband represents
and warrants to Wife that, since the date of separation, he has not contracted or incurred any debt or
liability, for which Wife or her Estate might be responsible, and shall indemnify and save Husband
harmless from any and all claims or demands made against her or her Estate by reason of debts or
obligations incurred by Husband and/or assumed herein.
4. CONTENTS OF THE MARITAL RESIDENCE
As of the date of the execution of this Agreement, the parties shall transfer and assign their
rights, title, claim and interest in specific property. Wife shall have as her own, free and clear of
any claims of Husband, all of the items, household goods, furniture, furnishings, appurtenances,
and appliances presently in her possession. Husband shall have as his own, free and clear of any
claims of Wife, all of the items, household goods, furniture, furnishings, appurtenances, and
appliances presently in his possession.
5. MISCELLANEOUS PROPERTY - PERSONAL REAL and MARITAL
It is further agreed that both Husband and Wife shall retain as his or her own any and all
personal effects, clothing, and personal jewelry. The parties further agree that any property not
assigned in this Agreement as marital or nonmarital property will be deemed the property of the
physical possessor of said property.
The parties own a parcel of land which is known as 339 Shed Road, Newville, Pennsylvania
17241. The parties agree to the following with regard to said real estate:
a) Said parcel of land is valued at $27,000.00.
b) Wife shall purchase Husband's interest in said real estate.
C) Wife shall pay $13,500.00 for Husband's interest in said real estate in the following
form:
D Page 3 of 14
` ' LD
a. Wife shall be credited $3,000.00 against the purchase price for the difference in
the parties' 401(k)s.
b. Wife shall pay Husband $291.66 for 36 months, beginning on December 1,2001
and continuing until the balance of $10,500.00 is paid in full.
d) Husband shall execute a deed in favor of Wife within 30 days of the execution of
this Agreement.
e) Said deed shall be held in escrow by either attorney of record in this matter.
6. RETIREMENT ACCOUNTS & LIFE INSURANCE
The parties shall keep all IRA's, 401 k's and other retirement accounts which are held in their
names as personal property, free and clear of claims from the other party.
The parties have maintained a life insurance policy (No. W63055010) with Monumental
Life Insurance Company on the life of Elliot Detwiler, Jr. The parties hereto specifically agree that
Husband and Wife shall become the co-owners of said policy with Wife being named the
irrevocable beneficiary. The parties hereto also specifically agree that their son, Robert A.
Detwiler, shall be the contingent beneficiary.
7. JOINT ACCOUNTS
The parties further specifically agree that all bank, savings, cash and checking accounts
shall become the sole property of party named on the account.
8. TAX LIABILITY
The parties hereto believe and agree that the division of property heretofore made by this
Agreement is a non-taxable division of property between co-owners rather than a taxable sale or
exchange of property. Each party promises not to take any position with respect to the adjusted
basis of the property assigned to him or her with respect to any other issue which is inconsistent
with the position set forth in the preceding sentence on his or her Federal or State income tax return.
dP ED Page 4 of 14
h:MLD
9. MUTUAL RELEASE
Subject to the provisions of this Agreement, each party waives his or her right to alimony
any further distribution of property inasmuch as the parties hereto agree that this Agreement
provides for an equitable distribution of their marital property in accordance with Pennsylvania's
Divorce Code. Subject to the provisions of this Agreement, each party has released and discharged,
and by this Agreement does for himself or herself, and his or her heirs, legal representatives,
executors, administrators and assigns, release and discharge the other of and from all caused of
action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had
or now has against the other, except any or all causes of action for divorce and except any or all
caused of action for any breach of any provision of this Agreement. Each party also waives his or
her right to request marital counseling pursuant to Pennsylvania's Divorce Code.
10. ALIMONY
Husband shall pay Wife alimony commencing on the effective date of this agreement.
Husband shall pay the sum of Ninety-Two Dollars and thirty one cents ($92.32) per week. Said
alimony obligation shall not be modified, suspended, or reinstated at the instance of request of
either party, or subject to further order of any court upon changed circumstances. Husband shall
also be responsible to make all payments for Wife's health insurance coverage.
Upon that condition, both parties hereby accept the provisions in this Agreement in lieu of
and in full and final settlement and satisfaction of all claims and demands that either may now or
hereafter have against the other for spousal support or alimony and both parties voluntarily and
intelligently waive and relinquish any rights to seek a modification, suspension, reinstatement, or
Q ED Page 5 of 14
=MLD
other court order with respect to the terms of this Agreement pertaining to the payment of support
or alimony.
Alimony awarded in this paragraph shall be terminated upon Wife's death, her marriage or
her involvement in a meretricious relationship.
11. ALIMONY PENDENTE LITE COUNSEL FEES AND EXPENSES
Both parties hereby acknowledge and accept that the provisions of this Agreement
providing for the equitable distribution of marital property are fair, adequate and satisfactory to
them. Both parties agree to accept the provisions of this Agreement in lieu of and in full and final
settlement and satisfaction of all claims and demands that either may now or hereafter have against
the other for alimony pendente lite, counsel fees any expenses during and after the commencement
of any divorce proceeding between the parties.
12. INCOME TAX RETURNS
Husband and Wife agree to file their tax returns using married but filing separate status for
this current year and each successive year until their divorce is final. The parties specifically agree
that any refunds and/or payments shall be the sole property of the recipient of the refund or obligor
of the payment.
13. WAIVER OF CLAIMS AGAINST ESTATES
Except as herein otherwise provided, each party may dispose of his or her property in any
way, and each party hereby waives and relinquishes any and all rights he or she may now have or
hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the
estate of the other as a result of the martial relationship, including, without limitation, dower,
curtesy, statutory allowance, widow's allowance, right to take intestacy, right to take against the
` D Page 6 of 14
?j MLD
will of the other, and right to act as administrator or executor of the other's estate. Each will, at the
request of the other, execute, acknowledge and deliver any and all instruments which may be
necessary or advisable to carry into effect this mutual waiver and relinquishment of all such
interests, rights and claims and both parties will revoke prior wills or testamentary documents.
14. AGREEMENT NOT PREDICATED ON 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 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 has been, may or shall be instituted by the other party, or from making any just or
proper defense thereto.
15. SUBSEQUENT DIVORCE
There has been a divorce proceeding commenced by Husband against Wife in Cumberland
County. The parties hereby mutually consent to a divorce and the entering of a divorce decree on
the no-fault grounds that their marriage is irretrievably broken pursuant to §3301(c) of the
Pennsylvania Divorce Code. Parties herein shall execute Affidavits of Consent and a final decree
in divorce will then be obtained.
16. BREACH AND ENFORCEMENT
ED Page 7 of 14
)?_ZNLD
If either patty hereto breaches any of the provisions of this Agreement, the other party shall
have the right to bring any actions or actions in law or equity for such breach, and the breaching
party shall be responsible for the payment of all costs and reasonable legal fees incurred by the
other party in enforcing his or her rights under this Agreement.
It is expressly understood and agreed by and between the parties hereto that this Agreement
may be specifically enforced by either party in Equity, and the parties hereto agree that if an action
to enforce this Agreement is brought in Equity by either party, the other party will make no
objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an
adequate remedy at law. The parties do not intend or purport hereby to improperly confer
jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum
of equity in mutual recognition of the present state of the law, and in recognition of the general
jurisdiction of Courts in Equity over agreements such as this one.
17. RE-ACKNOWLEDGMENT
Each party acknowledges that it may be appropriate and required that this Agreement be re-
acknowledged at some time in the future before the Clerk of the Commonwealth Court, Clerk of
Orphans Court or some other Court, and each party agrees that they will re-acknowledge their
signature before the Clerk of such Court upon request of the other party so that this Agreement may
comply with the acknowledgment rules and provisions of any such Court.
18. ADDITIONAL INSTRUMENTS
Each of the parties hereto agrees that he or she will join in the execution, acknowledgment
and delivery of any deed or other document which may be reasonably necessary to carry out the
intent of this Agreement, and, in the event either of the parties hereto would not join in the
d ED Page 8 of 14
MLD
execution, acknowledgment and delivery of such instrument, then such party does hereby
irrevocably appoint the other party hereto as his or her Attorney-in-Fact to execute, acknowledge
and deliver such instrument hereby ratifying all that such other party hereto may do by virtue hereof
with a copy of this Agreement to be a sufficient Power of Attorney to carry out the intent and
purpose of this paragraph.
Nothing contained in this section shall affect the right of one party to expressly include or
exclude, as the case may be, the other party as beneficiary in any will, insurance policy or other
document whether the same is presently in effect or would become effective in the future.
19• VOLUNTARY EXECUTION
The provisions of this Agreement and their legal effect have been fully explained to the
parties by their respective legal representatives, and each party acknowledges that the Agreement is
fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both
parties, and that it is no the result of any duress or undue influence. The parties acknowledge that
they have been furnished with all information relating to the financial affairs of the other which has
been requested by each of them or their respective counsel.
20. ENTIRE AGREEMENT
This Agreement contains the entire understanding of the parties and there are not
representations, warranties, covenants or undertakings other than those expressly set forth herein.
21. DISCLOSURE
Each of the parties hereto acknowledges that there has been full disclosure of all relevant
matters of each party to the other party, that each of the parties is fully cognizant of his and her
legal rights and liabilities with respect to the terms and conditions of this Agreement, that he and
ED
M L D
Page 9 of 14
I
she understand the legal effect of this provisions of this Agreement and acknowledge that this
Agreement is fair and equitable to each of the parties hereto, and that this Agreement was entered
into voluntarily and without any undue influence or duress upon either party hereto.
22. MODIFICATION AND WAIVER
This Agreement shall constitute a full, complete, and total binding Agreement between the
parties concerning support, maintenance, alimony and property settlement, and is precluded from
modification EXCEPT if the parties specifically agree to modify this Agreement.
Any and all modifications to this Agreement shall only be by written agreement containing
the same formalities as this Agreement and shall exhibit the notarized signatures of both parties,
along with two witnesses.
The parties specifically agree that they may rescind this Agreement only by written
agreement containing the same formalities as this Agreement which shall exhibit the notarized
signatures of both parties, along with two witnesses.
Any waiver of a breach of any provision of this Agreement shall not constitute an ongoing
waiver.
23. PRIOR AGREEMENTS
This Agreement constitutes the entire understanding and agreement between the parties
hereto, and there are no other representations, warranties, covenants, understandings or agreements
other than those expressly set forth herein.
D Page 10 of 14
c LD
24. INCORPORATION INTO DECREE )F DIVORCE
Unless as otherwise provided herein, this Agreement shall be incorporated in and made a
part of any Decree that might be entered in any dissolution proceeding between the parties hereto
upon the filing by either or both parties of an executed copy of this Agreement in such action and
same may be incorporated by reference into any such Decree or court order.
25. DESCRIPTIVE HEADINGS
The descriptive headings used herein are for convenience only. They shall have no effect
whatsoever in determining the rights or obligations of the parties.
26. INDEPENDENT AND SEPARATE COVENANTS
It is specifically understood and agreed by and between the parties hereto, that each
paragraph shall be deemed a separate and independent covenant and agreement.
27. APPLICABLE LAW
This Agreement shall be interpreted in accordance with the laws of the Commonwealth of
Pennsylvania.
28. VOID CLAUSES
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
29. AGREEMENT BINDING ON HEIRS
a ED Page 11 of 14
MLD
This Agreement shall inure to the benefit of and shall be binding upon the parties hereto,
their heirs, executors, administrators, successors and assigns.
30. EFFECTIVE DATE
This Agreement shall be considered to be effective at 12:01 a.m. on the date set forth on
page one of this Agreement.
In Testimony Whereof, witness the signature of the parties hereto this _4,1' day ofyt
2001.
*MOAWLDE ER
ELLIOT DETWILER, JR.
ML D
?!? - /Ctro
Witness for MO AN L. DEWILER
Witnnbssf ELLIOTDETWILE JR.
Page 12 of 14
STATE OF
COUNTY OF
SS.
On this, the !_S" Jay of 49-& ddnd 0... / 2001, before me, a Notary Public,
personally appeared MONA L. DEWILER and in due form of law acknowledged the foregoing
Property Settlement Agreement to be her act and deed, and desired that the same might be recorded
as such.
Sworn to and subscribed
before me this _L6 day
of Jq °..,E,.2001.
Notary Public
E rlor'Aw.sEU.PU8u 00
IIP.Wrj.=14f.U6 a
jq
I AYi ? ?'p O+E S n F 1+110.70 0 f?
e ` ED Page 13 of 14
?MLD
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
On this, the /4-day of A r"-V.4 I ,.2 , 2001, before me, a Notary
Public, personally appeared ELLIOT DETWILER, JR. and in due form of law acknowledged the
foregoing Property Settlement Agreement to be his act and deed, and desired that the same might
be recorded as such.
Swom to and subscribed
befor me this AC day
of 1? .ggmki-4,2001.
Nor?aw.ePx
VEM J. RICE. NOTAR
AMYCOMM188 PRE9 0
Notary Public
e'?6ED Page 14 of 14
LD
Law Offices of Lee E. Oesterling, LLC
42 East Main Street
Mechanicsburg, PA 17055
(717) 790-5400
IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT
CUMBERLAND COUNTY, PENNSYLVANIA
ELLIOTT DETWILER, JR.
Plaintiff,
V.
No. 99-771',] Civil Term
Civil Action - Divorce
MONA L. DETWILER
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed
on _._Au uct 9d 199R
2. The marriage of plaintiff and defendant is irretrievably broken, and ninety (90) 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.
1 verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to
authorities.
Date: o
ELLIOTT DETWILER, JR., Plaintiff
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Law Offices of Lee E. Oesterling, LLC
42 East Main Street
Mechanicsburg, PA 17055
(717) 790-5400
IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT
CUMBERLAND COUNTY, PENNSYLVANIA
ELLIOTT DETWILER, JR.
Plaintiff,
V.
MONA L. DETWILER
Defendant
No. 99-77ri rivii Te
: Civil Action -Divorce
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree 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. Section 4904 relating to unswom falsification to
authorities.
Date: ?/a L/o Z C?OL?c OQ?
ELLIOTT DETWILER, JR Plaintiff
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LAW OFFICES OF PETER J. RUSSO, P.C.
BY: Peter J. Russo, Esquire
PA Supreme Court ID: 72897
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
Telephone: (717) 591-1755
Facsimile: (717) 591-1756
Email: prusso@pjrlaw.com
Attorneys for Defendant
ELLIOT DETWILER, JR., : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-2261 CIVIL TERM
MONA L. DETWILER, : CIVIL ACTION - LAW
Defendant : DIVORCE
PLAINTIFF'S PETITION TO OPEN
Defendant, Mona L. Detwiler, by and through her attorneys, Law Offices of Peter
J. Russo, P.C., respectfully petitions this Court to open the above captioned matter. In
support of this petition, Defendant avers as follows:
1. On August 24, 1998, a Complaint under Section 3301(c) or 3301(d) of the
Divorce Code was filed in Cameron County.
2. On September 19, 1998, the complaint was served onto Defendant via
Certified Mail, Return Receipt Requested.
3. On March 5, 1999, a Motion to Transfer Divorce Complaint to Cumberland
County was filed, and an Order was thereafter entered by the Honorable Vernon D. Roof
granting the Motion to Transfer the docket to Cumberland County.
3. On December 26, 2001, a Stipulated Alimony Agreement and Equitable
Distribution was filed.
4. On April 5, 2002, Plaintiffs Affidavit of Consent and Waiver of Notice of
Intention to Request Entry of a Divorce Decree were filed.
5. On or about July 29, 2009, Defendant contacted the office of the undersigned,
requesting to have her divorce matter finalized.
6. The undersigned, unaware that the case had been terminated, attempted to file
Defendant's Affidavit, Waiver of Notice of Intention to Requested Entry of a Divorce
Decree and Praecipe to Transmit on or about August 28, 2009 and was thereafter notified
by the Prothonotary's office that the case had been terminated.
WHEREFORE, Defendant respectfully requests that this Court open the above-
captioned matter as it is the intent of Defendant to finalize the matter and a final Divorce
Decree be entered.
Respectfully submitted,
LAW OFFICES OF PETER IRUSSO, P.C.
Attorneys for ant
Peter J. Russo, Esquire
ID # 72897
Elizabeth J. Saylor, Esquire
ID # 200139
5006 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
PH: (717) 591-1755
FX: (717) 591-1756
Date: 1 3 C 0 ?
ELLIOT DETWILER, JR.,
Plaintiff
V.
MONA L. DETWILER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-2261 CIVIL TERM
CIVIL ACTION - LAW
DIVORCE
CERTIFICATE OF SERVICE
I, Amber L. Southard, hereby certify that I am on this day serving a copy of the
foregoing documents upon the person (s) and in the manner indicated below;
Service by First-Class Mail, Postage Prepaid, and Addressed as Follows:
Elliot Detwiler, Jr.
2905 Shortman Larne
James Creek, PA 16657
AWdx&&4
Amber L. Southard, Paralegal
Date: qj?juq
XFIGE
PROTHONOTARY
209 SEP -8 PM 1: 11
CUM&-:KLjV' -, CQNtY
PENNSYLVANIA
ELLIOT DETWILER, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
MONA L. DETWILER,
Defendant
NO. 99 - 2261 CIVIL TERM
ORDER OF COURT
AND NOW, this 15TH day of SEPTEMBER, 2009, it appearing to the Court that
the Petition to Open was not filed until almost four years after the case was terminated for
lack of activity, and it further appearing that the petition does not aver the facts required
by Pa. Rule of Civil Procedure 230.2 (d) (3) to justify reinstatement of the action, the
Petition is DENIED.
ZPeter J. Russo Esquire
,'--Elliot Detwiler, Jr.
,sld
Ql?s?oQ
Edward E. Guido, J.
OF THE
2009 SEP 15 AM 11: C, J
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Defendant Name: ELLIOTT DETWILER JR
Member ID Number: 814 910 015 7
Please note: All correspondence must include the Member ID Number.
ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS
Financial Break Down of Multiple Cases on Attachment
Plaintiff Name
MONA L. DETWILER
PACSES Docket
Case Number Number
352100593 99-2261 CIVIL
?..??ttX
Attachment Amou?ttguetk=
$ 400.00 -H
$ 1 r,t
C71
N
$ C-0
TOTAL ATTACHMENT AMOUNT: $ 400.00
--rb
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first
CD
Now, by Order of this Court, the Department of Labor and Industry, Office of Unemployment
Compensation Benefits (OUCB), is hereby directed to attach the lesser of $ 92.05
per week, or 50 %, of the Unemployment Compensation benefits otherwise payable to the Defendant,
ELLIOTT DETWILER JR Social Security Number XXX-XX- 8937 ,
Member ID Number 814 910 0157 . OUCB is ordered to remit the amount attached to the Department of
Public Welfare (DPW). DPW shall forward the amount received from OUCB to the Domestic Relations Section
of this Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for
support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total
amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. § 1673
(b)(2) and 23 Pa. C.S.A. § 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall remain in
effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for
Benefits dated JANUARY 2, 2 011 is exhausted, expired or deferred.
OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court.
All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this
Court.
BY THE COURT
Date of Order: JAN 1 1 2011
A?h?+ N . tJlaslcunc?, - JUDGE
Form EN-530 Rev.2
Service Type M Worker ID $ IATT
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225 Fax: (717) 240-6248
-?
Defendant Name: ELLIOTT DETWILER JR
Member ID Number: 8149100157 -r,. w
Please note: All correspondence must include the Member ID Number. { -,
=
ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFOS -n
Financial Break Down of Multiple Cases on Attachment
Plaintiff Name
MONA L. DETWILER
PACSES Docket
Case Number Number
352100593 99-2261 CIVIL
TOTAL ATTACHMENT AMOUNT:
Attachment Amount/Frequency
400.00 MONTH
400.00
The prior Order of this Court directing the Department of Labor and Industry, Office of
Unemployment Compensation Benefits (OUCB), to attach $92.05 or 50% per week of the
Unemployment Compensation benefits of ELLIOTT DETWILER JR, Social Security
Number XXX-XX-8937, Member ID Number 8149100157 is hereby vacated.
This Order to Vacate shall be effective upon receipt of the notice of the Order by the
Department and shall remain in effect until a further Order of the Court is filed.
BY THE COURT
Date of Order: JAN U 3 u" i4)
Albert H. Masland JUDGE
Form EN-035
Service Type M Worker ID $IATT
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225 Fax: (717) 240-6248
Defendant Name: ELLIOTT DETWILER JR
Member ID Number: 8149100157
c
a C70
`j
Please note: All correspondence must include the Member ID Number. -U:K --i--' 3
VACATE ATTACHMENT OF UNEMPLOYMENT I
BE TS)l
=c
a
?° 'n ?
cam
2C:) ate'
om
C- W -t
Financial Break Down of Multiple Cases on Attachment
Plaintiff Name
MONA L. DETWILER
PACSES Docket
Case Number Number
352100593 99-2261 CIVIL
TOTAL ATTACHMENT AMOUNT
Attachment Amount/Frequency
400.00 ! MONTH
1
$ 4UU.UU
The prior Order of this Court directing the Department of Labor and Industry, Office of
Unemployment Compensation Benefits (OUCB), to attach $92.05 or 50% per week of the
Unemployment Compensation benefits of ELLIOTT DETWILER JR, Social Security
Number XXX-XX-8937, Member ID Number 8149100157 is hereby vacated.
This Order to Vacate shall be effective upon receipt of the notice of the Order by the
Department and shall remain in effect until a further Order of the Court is filed.
BY THE COURT
Date of Order: JAN 0 IF ZU12
Service Type M
AlbW H Masland JUDGE
Form EN-035
Worker ID $IATT
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Defendant Name: ELLIOTT DETWILER JR
Member ID Number: 8149100157 c7
Please note: All correspondence must include the Member ID Number. -03 rv
Financial Break Down of Multiele Cases on Attachment D ° -v
Plaintiff Name
MONA L. DETWILER
PACSES Docket
Case Number Number
352100593 99-2261 CIVIL
TOTAL ATTACHMENT AMOUNT:
Attachment Amo;f&auWv
400.00 ?11IONM
400.00
Now, by Order of this Court, the Department of Labor and Industry, Office of Unemployment
--1
S
S Q
CD
^^p?. 9th
Compensation Benefits (OUCB), is hereby directed to attach the lesser of $ 92.05 per week, or 50%, of
the Unemployment Compensation benefits otherwise payable to the Defendant, ELLIOTT DETWILER JR
Social Security Number XXX-XX-8937, Member ID Number 8149100157. OUCB is ordered to remit the
amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received
from OUCB to the Domestic Relations Section of this Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or
Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so
that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to
15 U.S.C. § 1673 (b)(2) and 23 Pa. C.S.A. § 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall
remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the
Application for Benefits dated JANUARY 1, 2012 is exhausted, expired or deferred.
OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this
Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations
Section of this Court.
BY THE COURT
Date of Order: J!AI%d 10 2012
Ali H. Masud JUDGE
Form EN-530
Service Type M Worker ID $IATT
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N.HANOVER ST,P.O.BOX 320,CARLISLE,PA. 17013
Defendant Name: ELLIOTT DETWILER JR
Member ID Number: 8149100157 r" -
Please note:All correspondence must include the Member ID Number. J
ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BFI#
C r:1 or;
r
Financial Break Down of Multiple Cases on Attachment —�
Plaintiff Name Case Number Number Attachment Amount/Freouenc y
MONA L.DETWILER 352100593 111111111111, 400.00 / MONTH
$ /
TOTAL ATTACHMENT AMOUNT: $ 400.00
Now, by Order of this Court, the Department of Labor and Industry, Office of Unemployment
Compensation Benefits (OUCB), is hereby directed to attach the lesser of$92.05 per week, or 50%, of
the Unemployment Compensation benefits otherwise payable to the Defendant, ELLIOTT DETWILER JR
Social Security Number XXX-XX-8937, Member ID Number 8149100157. OUCB is ordered to remit the
amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received
from OUCB to the Domestic Relations Section of this Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or
Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so
that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to
15 U.S.C. § 1673 (b)(2) and 23 Pa. C.S.A. § 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall
remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the
Application for Benefits dated DECEMBER 29, 2013 is exhausted, expired or deferred.
OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this
Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations
Section of this Court.
BY THE COURT
Date of Order: JAN 0 6 2014
A(bOI1 H .Maasland JUDGE
Form EN-530
Service Type M Worker ID $IATT
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225 Fax: (717) 240-6248
Defendant Name: ELLIOTT DETWILER JR
Member ID Number: 8149100157
Please note: All correspondence must include the Member ID Number.
ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS
Plaintiff Name
MONA L. DETWILER
Financial Break Down of Multiple Cases on Attachment
PACSES Docket
Case Number Number -
352100593 99-2261 CIVIL
Attachment Amount/Frequency
400.00 / MONTH
/ ss.a
J•�
TOTAL ATTACHMENT AMOUNT: $
The prior Order of this Court directing the Department of Labor and Industry, Office of
Unemployment Compensation Benefits (OUCB), to attach $92.05 or 50% per week of the
Unemployment Compensation benefits of ELLIOTT DETWILER JR, Social Security
Number XXX -XX -8937, Member ID Number 8149100157 is hereby vacated.
This Order to Vacate shall be effective upon receipt of the notice of the Order by the
Department and shall remain in effect until a further Order of the Court is filed.
Date of Order: DEC 3 0 2014
Service Type M
BY THE COURT
Albert H. Maslar,d
DGE
Form EN -035
Worker ID $IATT
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Phone: (717) 240-6225 Fax: (717) 240-6248
Defendant Name: ELLIOTT DETWILER JR
Member ID Number: 8149100157
Please note: All correspondence must include the Member ID Number.
ORDER TO VACATE ATTACHMENT OF UNEMPLOYMENT BENEFITS
Plaintiff Name
MONA L. DETWILER
Financial Break Down of Multiple Cases on Attachment
PACSES Docket
Case Number Number
352100593 99-2261 CIVIL
C3 r•. a
Attachment Amount/.Erettpenciy— ,
400.00 /MVTH fr—
Fr.
$ 10) Cr
$ %� f\)
—t'
TOTAL ATTACHMENT AMOUNT: $ 400.00 c -Q
The prior Order of this Court directing the Department of Labor and Industry, Office of
Unemployment Compensation Benefits (OUCB), to attach $92.05 or 50% per week of the
Unemployment Compensation benefits of ELLIOTT DETWILER JR, Social Security
Number XXX -XX -8937, Member ID Number 8149100157 is hereby vacated.
This Order to Vacate shall be effective upon receipt of the notice of the Order by the
Department and shall remain in effect until a further Order of the Court is filed.
Date of Order: JAN 0 2 2015
Service Type M
BY THE COURT
Albert H. Masland
JUDGE
Form EN -035
Worker ID $IATT
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013
Defendant Name: ELLIOTT DETWILER JR
Member ID Number: 8149100157
Please note: All correspondence must include the Member ID Number.
ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS
Plaintiff Name
MONA L. DETWILER
Financial Break Down of Multiple Cases on Attachment
PACSES Docket
Case Number Number
352100593 99-2261 CIVIL
Attachment Amou illregdency
r.,
400.0T T -MON IB
cri - W
;f' C':
�ny
TOTAL ATTACHMENT AMOUNT: $ 400.00
C.)
Now, by Order of this Court, the Department of Labor and Industry, Office of Unemployment
Compensation Benefits (OUCB), is hereby directed to attach the lesser of $ 92.05 per week, or 55%, of
the Unemployment Compensation benefits otherwise payable to the Defendant, ELLIOTT DETWILER JR
Social Security Number XXX -XX -8937 , Member ID Number 8149100157. OUCB is ordered to remit the
amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received
from OUCB to the Domestic Relations Section of this Court for support and/or support arrearages.
If the Defendant's Unemployment Compensation benefits are attached by another Court or
Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so
that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to
15 U.S.C. § 1673 (b)(2) and 23 Pa. C.S.A. § 4348 (g).
This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall
remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the
Application for Benefits dated JANUARY 4, 2015 is exhausted, expired or deferred.
OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this
Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations
Section of this Court.
Date of Order: JAN 1 3 2015
Service Type M
BY THE COURT
Albert H. Masland
JUDGE
Form EN -530
Worker ID $IATT