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Home My WebLink About99-02557 '" " .~ I ") .. ~ : .~ v) '" "\ \ \ \ \ , , 1 , , I I , i I / ,/' .~ I I I I , i ~I I J ! l-i i ~I .ill '-i. t;" \t) ~ . C3' 0- ~l j .I .**.**~-**'~.~***~**~'~***')~'*"~~~**~'~~ : \ .---- - _.,-, ",.- --~~~-,,-,-,"-" - ,,--.- ,,",,----.-.------- --_._._-~! ~ ~l IN THE COURT OF COMMON PLEAS : ~ OF CUMBERLAND COUNTY S ~ . ,~, . STATE OF '?~~~. PENNA. _" ,.,.t....,.,,:-,......f ,..;-:,.,..!.'.~y.,(1.. ~l $ ~ ~ '.' CHRISTOPHER A. SIMES, ..... Plaintiff l\ (), .1999.::.2.5.57 $ ~ '.' * V<'I',"'US ~ TARA B. _ SIMES, ~ Defendant * .' ~ ',' $ DECREE IN DIVORCE AND NOW, ..j~...,.,\.._.,~..., it is ordered and decreed that....... ~.H~IST.OP. ~.R. .A~. S.~ME~.....,...".,.".., plaintiff, and... .~~~~..~:. S.IM~~........................ ............, defendant, are divorced from the bonds of matrimony. ~ $l ~ ~.~ ..; ~ ~.~ ~ ~.~ i ~.~ ~ ',' ~I vI ~ '.' The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ The. p.a.r:t;t~.s.'. .s~p,a.r:a tip,n ,Ag.r,eement . da.ted. October. ,20" .1994, .is . . . . , ere in , an.d . th.e .coll.rt . has jU!-"i,sq)>'}iot:\. 9y.e,. p.o. .Qth.e.r Iv. fJ y The / Ct?;? 1j.{.11 '" /../ ',/o{ .".._~. Vi.J ^t:h,l.fn /' ~ ,;, <:' * ~ ~ ~ ~ ,;, <;", ~ ~I '1 ~I ~I :I ( __ _... -'.._ - -- , -" --.. " , . :.:..:. .4ft;' .~.:. .;.> .:.;. .:.:. .:.:- .:.:. .;,,;. .:+;. ..:.:- -:.:- .:+:. .:.:. Prolhollot.1.ry ~ ... ~ ',' ~ ~.~ ,,~ * i ',' ~ ',- ~ ... ,'. ~ ,'. ~ ~ '.' ~ !~ * ~ ~i ~ '.' ~ .:. ~ ~ ~.~ ~ ~i ~ ~.~ ~; I~ !~ i~ ~~ ~~ 1 ,I,:. C a llll$ . I~ l~ I' \* I. ,~ J. ,'~ ~ I'" i:!- ~ .:+;. .:.:- .:.:- .:+;' -:.:- .:.~ .:.> .:.~. -:.: .:~> .:..:. .:.;. -:.:- <,,> .:+:. .:+:- [". C;'I \-, I'" ',' , . . ' " _ ':. ,'. , ' ,~" . . ". " :. " ',', . ',' ..' ," '.--4--< '---. '. WHEREFORE. Plaintiff requests the court to enter a decree of divorce. Respectfully submitted. ,~ ,/} / .' (t I /" ',- James l Kaye Esqvire Liberty Loft / / 4 Liberty Ave ue Carljsle. P A,J 013 (711) 243-7922 , " '. . "" ,~:.' .'," ..: . - .\. _ ' , l' ) ...: f' .. . - '; . (" J,~ ,.; n ~~>~ J-:t:f" (~,!: l'e, F:..l '-~ ~ ...,~ I.... e;I~!.r t.; C€) ~ c Qlfi ~.~ )> " 1Il r- '1l ~~n 0 2.~ -" "'C::: m CD .::::lg . la.'" ~:3 ,f)l. g Q) w~ m t>> ~ ~ ~c 0 Co ...,:>0'0"' N 5:)' m -a u..I' :l 0 .. ....."< .., 0 -J)> ~ "" C < _. < ..... en 0 ::s W::l ::l CO (I) CO (": (~ E:: o .;:I~ :1; f...)::;': . ,::~\~ :7j(O ~'.9 ~"L .' ::> u ... 2: t::, <'oJ f'- (;:: ~ c.'"\- (,!, "'-., ~ ..... ~ ~~ 1,,3 e; .t:l~ , 'I \1 ..., .,., \' . c4~J (' ~~ ~ .... c'- " .... ... . .~. ~ 1-J~ c....'-3 ~ a Lrt)l.f11' lolt V nuyer a.1f"~ n_ 'I l- UJU.-..... f-\.'rofes < vv n . 510n.11 Co . ~ E I rpor'::.tJOll ".,ilp 1y A . '. ),f'nup . C (i17) '1'4 ~ _( - ,1f!lslc' PA ,- t.. .)~,j22 . ,,013 . CHRISTOPHER A, SIMES, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 99 -2557 CIVIL TERM . ..' . . I; '.",. . ",' '. .' '. . < . '., . , : . . ': ~'~ \.' .:., ,: ')' . ~ ',' . ~ ' "'" , '. . vs. TARA B, SIMES, Defendant : IN DIVORCE AFFIDA VIT OF SERVICE BY MAIL PURSUANT TOPa. RoC.P. 1920.4(a)(1)(ii) COMMONWEALTH OF PENNSYLVANIA : SS, COUNTY OF CUMBERLAND I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff, CHRISTOPHER A, SIMES, and that he did serve a true and correct copy of the Notice to Defend and Complaint in Divorce that was filed in the above matter, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant, Tara Simes, on July 22,1999, The return receipt is attached hereto. Sworn to and subscribed before me tJI~s .;inA A(\i (YG ti}l.,\t ,:x{ her! . , ,,~ t (.-----1----:---. . ( \ \1. ,:, ( In ~{( I\'d)': \1 Notary Pub)ic ~. ........._._._..~..._~---_._--,.~ ~1~ ...J ~~ . < ~- ~ wz~z (J) ..0... -J;:fe <~;~ a: 0 '-.Jj ~~h o~e'" z:;;Sf (J).. c z~8 "'. OU~ .... J . I z g 3. MIel. MdrollSGd 10: "\on:" 'SII'Y\C'S \ CC'(dc 'Vc::,,\)\or l....c~(\<2 C.C'UC\ -\ ('JULIO \~,LL '3 ll!(\CI '::' lcdrj r\ . -Carr1Hl. ft~ 1 ~or2lor ~ MMoM. aComplatolt<<nl3, 4&. tnd 4b. aPnnl yolItWM..cI ~ on tho rrM'N 01 ChIt form to 1hM.. can rM1.n\ ItiI c:wcIm.-ou. .M-a, IhllIonn to the k'Otl of ltlt mIIIIpIeDI., Of on ttw ~. ~ doet nCJI _. 'wnte"A<<um R.o.Ipt ~Ol'llhe maIp6IoI below IhI &rtkM l"UT'lbIit 'Tha Aetfom ~.. -.o.'o.mm th, IIl'tide MIl ~ 1rICI1M", ......... 5, Rocolvocl By: (Pt1nf /<WnI) I 0010 wi"" 10 ~ lho IoIIowtng l&lVIceo (for lIIn oxtra IeO): j ,', I, 0 Md_'. A<lclr.- 2, ~ostridod DoIIYwy ConouIt poa_r lor ,... Q~'Nqr ssCrft 4b. SelVIco Typo E!l-RoOislOrod 0 Cartlftecl o Exprna Mal 0 lnourod ~ Rocoip( lor 1AIId1IM.. 0 COD 7. D"0ol~ 9~. 8. Mdro....'. 1Id:1r... (Oo1y II requNt8d ~ _100 Is paid) ~ .. '~';i-8.o11li1 GG6L"8VG (nIl 8 ~OI ~ Vd 'aIS!lm:) . anUG:,V ^P8'l'l '3 t, . ljOl '~lJaql"l LJo)leJodJ08 IUUOISSiJ;OJd \j UMOJ8 pue Jalie>f > ., , Ql :J C(") C <= Ql~ .9 >0 == ~ <l:.... >.~ 0 0 tcaC\J ... e- 0>._ C\l III .0 Co> 0 .- co,....., '0 () -'>, ;;; '>.M C w"'"" C ""C{\j I'll .9 . &iF=: ... '" CIl '" Q.'~ ;t:: -I:::. >..J!! o Ql I'll e -'ii; :li:::Q. >.:e 1::", <l: ~U :::; " , ,~ GG6L-SVG (HL) S WL ~ lid 'OIS!IJ8::l . onuf\^1i ^lJoqn '3 V . HOl ^lJoqil UO!lBJodJO::lIUUO!SSOJOJd Ii UMO.l8 'pUt:? :Aafie)l .' c: ;:2 ;;>> ~ o '" ... c. aJ 0 "0'" -iii ... c: 111 0 _ '00 Cl) l(l >- ~- 111 e ~o.. <.( Q) ::> c:'" Q)~ ~R ~:C\J Q).- N .oc", ;:j~li'" . >.(0) W"'..,. ..,.cC\J c~ . Q) r--. ;::D.:t; o Q) -Ju; ~~ ~'" :J 0 \l) i'~'" f~' 1..;. , , "':.1 .. " r'.! "":J . :',:] ." '., , ',,::.- .' , 0.) ~~:'.;' .~ 0.' c r.:.: (. J~-;J > -;" '- ., ;. (-, {j f.: ':':' .~: f,., '.-' ~< ,. :~~ (::> ~, -, . ,....,..;,', ',' '. , ' ,. c" ", " " . - " ' ., ,l" . ,:, '. ". , , , 1 i 1 ,! ! 1""''''1 ("'"', SEPARATION AGREEMENT 2 -,I, Q THIS SEPARATION AGREEMENT, made this () day of frlo b!J.-r" , 1994 by TARA BATRICE SIMES, hereinafter referred to as the Wife, and CHRISTOPHER ALLEN SIMES, hereinafter referred to as the Husband: WITNESSETH: WHEREAS~ the parties hereto were married on September 3, 1989, at Ford Heights, Illinois; WHEREAS, there are children of the marriage, namely DOMINIQUE M. M. SIMES, born December 19, 1990, and DANA L. SIMES, born October 7, 1993, hereinafter sometimes referred to as the parties' children. WHEREAS, irreconcilable differences have arisen between them, on account of which the parties have separated on October 20, 1994 and now live separate and apart and intend to live separate and apart from each other for the rest of their lives; WHEREAS, it is the desire of both finally to settle their respective property rights and all rights of support; and NOW THEREFORE, in consideration of the mutual promises herein made the parties agree as follows: ARTICLE I SEPARA'.rION 1. SEPARATION OF THE PARTIES: The parties may and shall continue to live apart for the rest of their lives. Each shall be free from interference by the other as fully as though unmarried. Each may reside at such place or places as he or she may select. Neither party shall molest the other or endeavor to compel the other to cohabit with him or her. 2. EFFECT OF RECONCILIATION: If the Husband and Wife reconcile, either by living together as husband and wife, or by having sexual relations, prior to divorce, then this Agreement, except for provisions in regard to separate property, as far as it concerns unexecufed provisions will become null and void. r ( (])~ ^. J l~ 1 \(1 ) (lll ~J)\. ~'-~ ~ / ,- ' .,~ ....' ',' - .' . . .. '., . . . . .-. ~ ARTICLE II PROPERTY 1. DIVISION OF PERSONAL PROPERTY: The parties have heretofore divided their personal property to their mutual satisfaction. Henceforth, each of the parties shall own, independently of any claim or right of the other, all items of real and personal property now or hereafter owned by him or her, with full power to dispose of same as fully and effectually as if he or she were unmarried. Specifically the following items of personal property have been divided between the parties as provided herein: a. Furniture and Other Tangible Property: The Wife shall have all of her personal clothing and effects, and the below listed items as her sole and separate property: Magnavox 27" television JVC ta,pe deck JVC CD player JVC VCR Symphonic VCR Infinity speaker and sub system Speaker stand Emerson microwave Convection oven Living roomf urniture consisting of sofa, love seat, chandlier, end tables, lamps, entertainment center All fish tanks Queen size bed, 5 drawer dresser with mirror and two small five drawer dressers Polaroid camera Half of the tapes and CDs as divided by the parties Half of the Linen, blankets, sheets and towels as divided by the parties b. Furniture and Other Tangible Property: The Husband shall have all of his personal clothing and effects, and the below listed items as his sole and separate property: 19" Broksonic television 13" JVC television Sansui receiver and equalizer Pioneer speakers and Surround Kenmore washer rf;~e ~\" , speakers \ I '\ 'l I . r \ ~("'" , V I I 'I 'U",/).. /J'; ...,.. I ! / r"',,\ (""'" ~ ' ' , ' ".' _ . ~ . ;. , ' .' '>, , ,~.' ." .' ~, I, " " "1 , ~. " -.. ~ J J.: .... , Hitachi VCR All small kitchen appliances owned by the parties except the convection oven and microwave Small entertainment center Minolta camera Nintendo and all games Queen size bed and large dresser Half of the tapes and CDs as divided by the parties Half of the Linen, blankets, sheets and towels as divided by the parties c. Automobile: The 1994 Hyundai Excel, serial number KMHVF22J9RU975815, which is subject to an existing lien, shall be the sole and separate property of the Wife, and the Husband shall make payments on the lien note. d. Automobile: The 1987 Chevrolet Spectrum, serial number J8lRF217lH8488509, which is not subject to an existing lien, shall be the sole and separate property of the Husband. e. Personal Effects: All items of personal effects such as, but not limited to, clothing, jewelry, luggage, sports equipment, hobby collections and books, but not including furniture or any property, personal or otherwise specifically disposed of pursuant to this agreement, shall become the absolute and sole property of that party who has had the principal use thereof or to whom the property was given or for whom it was purchased, and each party hereby surrenders any interest he or she may have in any such tangible personal property of the other. f. Intangible personal property (other than life insurance): All stocks, bonds, cash, and sums on deposit in checking and savings accounts (owned by either party) shall be divided as soon after execution of this agreement as practicable in the following manner: (1) Bank Accounts: All sums on deposit in Fi.rst Union Bank, checking account number 1065300076163, Fort Bragg Credit Union, savings account 348-58-7715, and Pentagon Credit Union, account 2095928-01-2, in excess of outstanding checks as of the date this agreement becomes effective, shall become the sole and separate property of the Husband. (2) Bonds: All bonds held by the parties as of the date of separation shall be split equally by the parties. The Husband shall retain as his sole and separate property, the United States Savings Bonds obtained after the date of separation. (j4 A,~ v~ 3 . / ..... , 1 ~, (3) Pension Rights: have a claim to the Husband's return for the rights granted expressly waives any claim to The Wife realizes that she may pension rights; however, in her by this agreement, she the Husband's pension. 2. ACCEPTANCE AND MUTUAL RELEASE: Each of the parties receives the property set apart to them and the undertakings hereof in full and complete settlement and release of all claims of every kind. 3. WAIVER OF CLAIM AGAINST ESTATE: Each party hereby waives and relinquishes any rights that he or she may now or hereafter have to share as spouse in the other party's estate (including any right of election to take against the Will), or to act as legal representative thereof. 4. WAIVER OF EQUITABLE DISTRIBUTION: By this agreement both parties have settled all questions concerning this distribution of their property and hereby expressly waive any rights they may have to equitable distribution by a court. They agree that the distribution of property contained herein is fair and equitable. ARTICLE III CUSTODY OF THE CHILDREN The parties shall share joint custody of the children with primary physical custody being with the Wife, subject to reasonable visitation rights vested in the Husband. ARTICLE IV REASONABLE VISITATION The Husband shall exercise visitation rights by notifying the Wife in writing or telephonically of his intention to do so, in advance, to obtain the Wife's consent, which the Wife shall not unreasonably withhold from the Husband. CL~. ~ L 4 I\,! /\ .. . )('el...!'\' / I rl<.IJ.- "11 I . " . , . . ," , . ' ., -, ~. '. ' "-'-- - '," " . - " ~ ," . ....... , ,,-.. ARTICLE V CHILD SUPPORT 1. AI.LOWANCES TO THE CHILDREN: The Husband agrees to pay the Wife or other persons having care of the children in the wife's custody, beginning January 1, 1995, the sum of $426 per month, or the amount of his BAQ at the with dependents rate, as he increases in rank or the amount of the BAQ incr.eases, for the maintenance and support of the children, during the period when they are in the Wife's custody. Support for each child shall terminate upon the occurrence of any of the following: Upon the death of the Husband, or death of a child, or any child reaching the age of eighteen years of age, or upon any of the following acts: adoption by another party, joining the U.S. Military, or marriage, whichever shall first occur. 2. LIFE INSURANCE: The Husband agrees to pay the premiums and to maintain in full force and effect his present insurance on his life or its equivalent payable to the children in a net amount of $100,000 for each child for so long as the Husband is obligated to pay child support to the Wife or other persons having care and custody of the children in the Wi.fe's custody. ARTICLE VI ALLOWANCES TO THE WIFE 1. The Husband agrees to pay the Wife until she dies or a final divorce is granted, the sum of $65 per month, plus make the car payment on her automobile as herein set out as alimony for a period of one year following the execution or this agreement. When the above payments have been paid for one year, Husband will make the car payment on Wife's automobile as alimony. Upon the payment of the car payments in full, all alimony payments shall cease. 2. The Wife will, for herself so long as eligible, utilize medical and hospital services available to her under the Armed Forces Medicare Program. Subsistence and other charges incident to the use of Medicare by the Wife shall be paid by the Wife. Cllli- A -~\~ 5 " ~, It ,\;! J / , " Jj ") , l \ " )(/h__'I.)-..... '. .' .~~ ' , . ';" " . ,.' '.' , , . .~~:, .'., ' .,.., , . ", '-'. - '. .'" " 1'01"", (' ARTICLE VII MILITARY PRIVILEGES The Husband shall assist in arranging for the Wife's use of military facilities and privileges to the extent which she is, by law, entitled to use them. The parties understand that the eligibility of the Wife to use such privileges terminates upon final divorce. DEBTS ARTICLE VIII 1. Each party shall be solely liable for the payment of all debts incurred by such party on or subsequent to the date of this agreement. 2. Should either party hereafter be requested to pay any debts of their spouse for which they are not liable under the terms of this agreement, he or she may pay such debts and charge the payment as a credit against allowances for the spouse. Present outstanding debts for which the Husband assumes responsibility are: CREDITOR Hyundai Motor Company, 11371650001-3 AAFES, 348-58-7715 Avco, 447500780 Circuit City, 1727204501891731 Sallie Mae Financial Service 348-58-7715 AMOUNT $10,462 - monthly payment $234.99 $1,800 - monthly payment $77 $1,800 - monthly payment $125 $694 - monthly payment $23 $22,500 - monthly payment $50 3. Present outstanding debts for which the Wife assumes responsibility are: CREDITOR Visa, 4428-1351-3821-7647 Master Card GE, 5407-5613-6007-10087 Master Card, Cornerstone , ~ (L~.. ~ '">; ~rN-. AMOUNT $1,200 - monthly payment $12 $496 - monthly payment $12 $3,000 6 ' \\ n L, J{\ '---{'I ,C) 'i~ . "..' . j :' ". ,:~':~_'~~~""-:':' " " ,. ',,' . ',.'~ ~' ..' ,\ ," ": 'I \' , "'" ....., .-, ARTICLE IX TAXATION Unless mutually agreed to the contrary, the parties shall file their income taxes jointly until they are divorced. Thereafter, the Wife agrees to execute a Release of Claim to Exemption for the Child of Divorced or Separated Parents, Form 8332, by January of each year in favor of the Husband for one of the minor children of the marriage, and the Husband agrees to execute a Release of Claim to Exemption for the Child of Divorced or Separated Parents, Form 8332, by January of each year in favor of the Wife for one of the minor children of the marriage. ARTICLE X MISCELLANEOUS PROVISIONS 1. PRIOR AND SUBSEQUENT AGREEMENTS: The parties hereby cancel any prior property settlements they have made. All modifications of this agreement shall be of no effect unless expressed in writing and signed by both parties. 2. ENTIRE AGREEMENT: Both the parties have been advised of their right to independent counsel, free of charge, through the U.S. Anny. The parties have been advised by their attorneys of both the legal and practical effect of this agreement. The parties acknowledge that the agreement is fair. There are no promises or agreements not set forth in this written agreement. 3. BINDING EFFECT: All prov1s1ons contained herein shall apply to the heirs, executors, and assigns of the parties hereto. 4. ADDITIONAL INSTRUMENTS: Each of the parties shall promptly execute and deliver such written instruments as may be required from time to time to carry into effect fully the terms of this agreement. 5. CHOICE OF LAW: This agreement was negotiated and entered into in North Carolina. It is agreed that any questions concerning this agreement shall be controlled by the law of North Carolina. 6. ENFORCEMENT PRIOR TO DIVORCE: The Nife agrees that she will not contact, either directly or indirectly, the Armed Forces or her Husband's Command'ng Officer with respect ~~.~,;~ 7. ) J r. ""'" , , 1"'"''1 STATE OF NORTH CAROLINA COUNTY OF CUMBERLAND On this '20 -In day of Q -Iv hl'/r 19 q;/-, before me -=';u CL,,;:f..!:.. y, /:2nJUJr? the undersigned Notary Public, personally appeared TARA BATRICE SIMES known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instruments and acknowledged that she executed the same for the purposes therein contained. (SEAL) My commission expires: STATE OF NORTH CAROLINA COUNTY OF CUMBERLAND /) 'tl? -J:l /':\. / On this ,aJ day of ! -Iv b/l.r 19 '-1'T, before me -JI,On,.-ItJ., '* -Yi->>n the undersigned Notary Public, personally appeared CHRISTOPHER ALLEN SIMES known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instruments and acknowledged that he executed the same for the purposes therein contained. (SEAL) ,wu 1 ~J Try PUBLIC expires: (P - 2. t ..qq My conunission {-L ~ /, I \. - / "~1-'~ .t 9 s .,':.~' "', . "',.~,.:,~".:. ,,'" ::'/,'" "..~', ", ,.\~'. :' ,::'... . '",';: ':" CHRISTOPHER A, SIMES, Plaintifr, IN THE COURT OF COMMON PLEAS OF CUMBI<:RLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN DIVORCE v. NO. 99-2557 CIVIL TERM TARA B. SIMES, Defendant. CERTlFICA TE OF SERVICE I, Todd Greene, a Certified Legal Intern at the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition for Leave to W ilhdraw on the following persons by first class, United States mail, postage prepaid, this 2nd day of December, 1999: Tara B, Simes, 18066 Poplar Lane, Country Club Hills, 1160474 and James J, Kayer, Esq., attorney for the Plaintiff, Christopher A. Simes, at4 East Liberty Avenue, Carlisle, Pennsylvania 17013, !Ill<-- Todd Greene Certified Legal Intern Family Law Clinic 45 North Pill Street Carlisle, PA 17013 (717)243-2968 Fax: (717)243-3639 > . '. . . ' ,M., ' ' ',I ,~' ,,' .. , . .' . . ' ~ . . ' .', ". '. l'. _ ' .' . . . . consisted of a telephone call on October 20. 1999, 7. Ms. Simes lack of contact with the Family Law Clinic has made further rcpresentation of her unreasonably difticull. WHEREFORE. The Family Law Clinic requests permission to withdraw as counsel for Ms, Simes in this matter. Date: December 2. 1999 Respectfully Submitted. Family Law Clinic 45 North Pill Street Carlisle. PA 17013 (717)243-2968 Fax: (717)243-3639 . . ."".,., " I", _ : ' "" .,1,."" ," , .' i,. , >- r-. ~ c;; U') Ie; -- ~-. S? " ,)..~ !JJ~~ , , ),~, ~!r-: , ~ "-T .'- '- :.::. '.j., ~" ,-.'i ~~=.! (,.J{ C)t~ ("J ':/) 1...l.1., I .-~) ;-.; :'''--'1 , c..; . :-j :"1] l4__ Ll.' !O.... I,:: c, ~ !- C"l :j U en U CHRISTOPHER A. SIMES. PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE ~ss7 NO, 99-2m CIVIL TERM v. TARA B. SIMES. DEFENDANT PRAECJ1>E TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Tara B, Simes. the Defendant in the above captioned matter, Jii~ Tod Greene ~t;Jr~ ROBERT E. RAINS THOMAS M. PLACE KATHERINE C. PEARSON Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle. PA 17013 717/243-2968 717/243-3639 () ,./.M,,,,,, 20 _ 19~ , , ,:, .'. ,'.' ',' ..,. , ..... C) ~ ~ c f-- :~)<t': w~~ 0=" c.)""- -- (:)0 ti: ~',) .- '" 'I _. ..-:: ;~)~ ~f-. -:-::- C) :~. fJ) .)z JIL N rez -'I ' : I- ~ dUJ CCc; c...:: '.:)(1., ,,, 0 -..;. !.l_ en .5 0 (j) u >- w E; ~ ...::J ~- c'J :5.,- UJ!J C)~-: ~~(' x: ():g: ftl CJ.. ::~)~ <<'?{I N ;,.~ (':l( .. :r_. u',l' Ir.:Z _.1" . -l ~Jl.U L:.'" :1: :'::J "JQ,. 1- -, ''; ~ C1l ~ en U