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HomeMy WebLinkAbout99-03908ti .e y z h 1 t C" ci be a O` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF f PENNA. David L. Williams, Plaintiff No. 99-3908 cimil . I VERSUS Melinda M. Williams, Defendant DECREE IN DIVORCE AND NOW, L? 2000, IT IS ORDERED AND DECREED THAT David L. Williams PLAINTIFF, AND Melinda M. Williams DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; None PROTHONOTARY Lid el /,V 'a , a4 30 m we-a,-Zee- iuy z a4 ??" a , DAVID L. WILLIAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA. V. NO. 99-3906 CIVIL MELINDA L. WILLIAMS, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a Divorce Decree. 1. Ground for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: On June 25, 1999 by acceptance of service. An Acceptance of Service has been filed with the Prothonotary's Office. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on March 27, 2000; by Defendant on March 30, 2000. 4. Related claims pending. None. All economic issues were resolved by property settlement agreement between the parties dated March 27, 2000. Page 1 of 2 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: April 26, 2000. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: April 26, 2000. 4 f/Ac z- Kent H. Patterson Attorney for the Plaintiff 221 Pine Street Harrisburg, PA 17101 (717)238-4100 Dated: ?d IJ Page 2 of 2 _ i I . t _i .. :i U DAVID L. WILLIAMS, Plaintif £ v. MELINDA M. WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 390e CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so the case may 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. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Dauphin County Courthouse, Front & Market Streets, Harrisburg, Pennsylvania 17101. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17013-3387 (717) 240-6200 DAVID L. WILLIAMS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99- 390? CIVIL TERM MELINDA M. WILLIAMS, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes Plaintiff, David M. Williams, by his attorney, Kent H. Patterson, and files this Complaint in Divorce, based upon the following: 1. Plaintiff, David L. Williams, is an adult individual who resides at 872 Country Club Road, Camp Hill, East Pennsboro Township, Cumberland County, PA 17011. 2. Defendant, Melinda M. Williams, is an adult individual residing at 872 Country Club Road, Camp Hill, East Pennsboro Township, Cumberland County, PA. 17011. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 24, 1999 in Las Vegas, Nevada. 5. There have been no prior actions for divorce or annulment between the parties. 6. Plaintiff and Defendant are both citizens of the United States of America. 7. Defendant is not a member of the Armed Services of the United States or any of its allies. 8. Plaintiff avers as the grounds on which this action is based are that the marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between Plaintiff and Defendant and such further relief as the Court may determine equitable and just. K nt H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 -2- VERIFICATION I, David L. Williams, verify that the statements in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. David L. Williams Date: 6 Ig 5 lgq :? ?= ? - , ?, , ` .. _ ?,?? ,_ ?? ?, ;. ",- "? ???? ? ? n M DAVID L. WILLIAMS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No. 99-3908 CIVIL TERM MELINDA M. WILLIAMS, Defendant IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Complaint was filed on June 25, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate, in counseling. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. 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 IS Pa. C.S. 54904 relating to unsworn falsification to authorities. 3 1 a r7' o o,? ?- Date David L. Williams i .- J J DAVID L. WILLIAMS, Plaintiff V. MELINDA L. WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 99-3908 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 4909 relating to unsworn falsification to authorities. 3 ?aa,-7/ou Ak-lda .? Date David L. Williams ?_ DAVID L. WILLIAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA. V. NO. 99-3908 MELINDA L. WILLIAMS, Defendant IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Complaint was filed on June 20, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. 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. 54904 relating to unsworn falsification to authorities. Ak(- (uv Date Melinda dams a/k/a Melinda M. Erway WZ04i W. ow- ,, DAVID L. WILLIAMS, Plaintiff V. MELINDA L. WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 99-3908 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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, lawyers 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 4909 relating to unsworn falsification to authorities. 3(3e I,,. Date elinda M. Williams, u G a )a Melinda M. E vay ?, J n DAVID L. WILLIAMS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 3908 S 1999 MELINDA M. WILLIAMS, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. MM. Williams 872 Country Club Road Camp Hill, PA 17011 or 8700 E. University Drive, #2565 Mesa, AZ 85207-6800 ?a? 99 Date: 6 Cj o WQ o co 2 L uJ 1' :'s' 7_ !1 ?? 11 Q x O cr% % a U J i VS. m. WIXIA?s ??VA?f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Rl i ?j J7 y CIVIL 19 IN DIVORCE STATUS SHEET n A'1`v- I Af TTVTTTF.S- Cyr ? ? DAVID L. WILLIAMS, Plaintiff VS. MELINDA M. WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 3908 CIVIL IN DIVORCE TO: Kent H. Patterson Emily Long Hoffman? Attorney for Plaintiff Attorney for Defendant DATE: Wednesday, January 12, 2000 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. ?y (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, 11 Divorce Master Traci Jo Colyer Office Manager/Reporter West Shore 697.0371 Ext. 6535 February 25, 2000 Kent H. Patterson, Esquire 221 Pine Street Harrisburg, PA 17101 Emily Long Hoffman Attorney at Law P.O. Box 11475 Harrisburg, PA 17108-1475 RE: David L. Williams vs. Melinda M. Williams No. 99 - 3908 Civil In Divorce Dear Mr. Patterson and Ms. Hoffman: Mr. Patterson has written a letter indicating that he does not believe discovery will take 120 days to complete; however, I do not want to totally ignore attorney Hoffman's indication that discovery will take three months. Consequently, as a way of trying to move this case forward and compromise the positions of the attorneys, I am going to issue a directive for pretrial statements. I am also persuaded by the fact that this is a marriage, according to Mr. Patterson, of only one month. This case should move forward expeditiously and should not require extensive computation to produce values of marital assets. In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to file a pretrial statement on or before Friday, April 14, 2000. Upon receipt of the pretrial statements, I will immediately schedule a pre- F Ji ? err ,r Sa 4 `iM MR. PATTERSON AND MS. HOFFMAN$ ATTORNEYS AT LAW 25 FEBRUARY 2000 PAGE 2 hearing conference with counsel 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 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. f`1. IN THE COURT OF COMMON PLEAS OF CU;FBERLAND COUNTY, PENNSYLVANIA DAVID L. WILLIAMS Plaintiff VS. MELINDA M. WILLIAMS Defendant NO. 99-3908 CIVIL TFRM19 MOTION FOR APPOLq=T OF MASTER David L. Williams (Plaintiff) $C zzdmX), moves the court to appoint a master with respect to the following claims: (x) Divorce (x ) Distribution of Property ( ) ) Annulment ( ) Support (x Alimony ( ) Alimony Pendente Lite (x ) Counsel Fees (x ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims(s) for which the appointment of a master is requested. nnt (2) The defendant (has) 6}g-vxp?) appeared in the action (personally) (by 36 attoraey,r?Emi ,Esquire). Th marria following claims claims: or fact. I staturory ground(s) for divorce (is) (are) irretrievably broken Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the none The action action contested not issues or law (6) The hearing is expected to take 3-4 hours (hours) (days). (7) Additional information, if any. relevant to the motion: The parties separated after one month of ma-------- Date: 12/29/99 Attornev for (Plaintiff) Kent H. Patterson (?Ami=) ORDER APPOINTING }FASTER AND NOW , _z' f pj? 11 e f !fit/apt Esquire, is appointed .er th respect to the following claims: Q p Z By t C r J respect to the -?QJ,4m azlLo A 1-16-00 R?6 KENT H. PATTERSON ATTORNXV AT LAW 99119NESTRI:HT IIARRISHURM PHNNSYLYANIA 17101 TELEI•HONE February 18, 2000 E. Robert Elicker, II, Esquire Office of Divorce Master Cumberland County 9 North Hanover Street Carlisle, PA 17013 RE: David L. Williams v. Melinda M. Williams No. 99-3908 Dear Mr. Elicker: Enclosed is the certification for the Plaintiff, David L. Williams, that you requested concerning discovery in this case. Please note that there are only a few items of discovery that the Plaintiff is requesting from Defendant and which Defendant should be able to provide in less than 30 days. In reviewing the certification submitted by Attorney Hoffman on behalf of the Defendant Melinda Williams, most of these items have already been provided to Attorney Hoffman. We submitted documentation concerning Mr. Williams' assets and the 1998 Income tax returns and paychecks were submitted at the support conference at the Domestic Relations Office. The 1999 income tax returns are not yet prepared or filed. We previously advised Emily Hoffman that Mr. Williams does not have W-2 forms for 1998 and that he believes Mrs. Williams took them along with other financial records. We ask that she return them to Mr. Williams. The only items remaining to be produced are the 1999 W-2 forms which will soon be available from Mr. Williams' employer and a copy of the last paycheck stub for 1999 which can be produced. Under the circumstances, Attorney Hoffman's request for 120 days to finalize discovery is not necessary and would only serve to unnecessarily delay this case. All discovery can be completed in less than 30 days. Would you please issue a pre-trial directive and schedule the pre-trial conference as soon as possible. This was a short marriage of only one month and is an uncomplicated case. Delaying the case will be prejudicial to Mr. Williams. i E. Robert Elicker, II, Esquire February 18, 2000 Page two Thank you for your consideration. KHP/ct cc: David L. Williams Emily Long Hoffman, Attorney at Law very truly yours, . Kent H. Patterson DAVID L. WILLIAMS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 99 - 3908 CIVIL MELINDA M. WILLIAMS, Defendant IN DIVORCE TO: Kent H. Patterson Attorney for Plaintiff Emily Long Hoffman Attorney for Defendant DATE: Wednesday, January 12, 2000 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. Identification of all pension and retirement plans in which Plaintiff has an interest, along with copies of all statements for said plans for the year 1999 to the present and copies of plan documents and brochures. A (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. 30 days DATE COUNSEL FOR PLAINTIFF (xx) 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. DAVID L. WILLIAMS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-3908 CIVIL TERM MELINDA M. WILLIAMS, CIVIL ACTION - LAW Defendant IN DIVORCE DEFENDANT'S RESPONSE TO PLAINTIFF'S DIVORCE COMPLAINT AND NOW comes the Defendant, Melinda M. Williams, by her attorney, EMILY LONG HOFFMAN, and in response to Plaintiff's complaint avers and counterclaims as follows: 1. Agreed. 2. Agreed. 3. Agreed. 4. Agreed. 5. Agreed. 6. Agreed. 7. Agreed. 8. This is an averment to which no response is required and therefore is deemed denied. 9. This is an averment to which no response is required and as such is deemed denied. 10. Paragraphs one through nine of Plaintiff's complaint and Defendant's response thereto are incorporated herein as if fully set forth. 11. By reason of this action, Defendant has been put through considerable expense in the preparation of her case and the employment of counsel and the payment of costs. 12. The Defendant is without sufficient funds to support herself and to meet the costs and expenses of this litigation. 13. Defendant's income is not sufficient to provide for her reasonable needs and to pay her attorneys' fees and the cost of this litigation and she is unable to appropriately maintain herself during the pendency of this action. 14. Plaintiff has adequate earnings to provide for the Defendant's support and to pay her counsel fees, costs and expenses. 15. Defendant lacks sufficient property to provide for her reasonable needs. 16. Defendant is unable to support herself through appropriate employment. 17. Plaintiff has sufficient income and assets to provide continuing support for the Defendant. EQUITABLE DISTRIBUTION 18. Paragraphs one through seventeen of Plaintiff's complaint and Defendant's response thereto are incorporated herein as if fully set forth. 19. Plaintiff and Defendant possess various items of marital property which is subject to equitable distribution by this Court. WHEREFORE, Defendant prays this Honorable Court enter an Order making equitable distribution of the marital property and awarding her alimony, alimony pendente lite, counsel fees, expenses and costs. Respectfully submitted, By: trNr EMILY LONG HOFFMAN, ESQUIRE Sup. Ct. I. D. #66307 105 North Front Street P. O. Box 11475 Harrisburg, PA 17108-1475 (717) 233-1112 DATED: July 20, 1999 COMMONWEALTH OF PENNSYLVANIA ) ) SS.: COUNTY OF CUMBERLAND ) AFFIDAVIT Melinda M. Williams, being duly sworn according to law, deposes and says that the facts contained in the foregoing Response to Plaintiff's Divorce Complaint and Counterclaim are true and correct to the hest of her ??k--noowledgee, information and belief. Date: 7/20 / q 9 /2y/-U?- cc6j Melinda M. Williams a a> , ` C r - c:):. LL. [1I'. :1 C\I L' C \ :J DAVID 1., WILLIAMS, Plaintiff/Respondent VS. MELINDA M. KRWAY, Del'enda ni/Pel it ioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 99 - 3908 CIVIL TERM IN DIVORCE DR# 28,998 Pacscs# 899101498 ORDER OF COURT AND NOW, this 12°i day of October. 1999, upon consideration of the attached Petition for Alimanv Pendenlc Life turd/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R. J Shaddav on October 27, 1999 at 10.30 A.M. for a conference, at 13 N. I hutover SI . Carlisle. PA 17013, after which the conference officer may recommend that an Order for Alnuonv I'endente Lile be entered. YOU tire furl her ordered to bring to the conference: (1) it true copy of your most recent Federal Income Tax Return, including W-2's as fried (2) your pay stubs for the preceding six (6) months (1) the Inconc and Expense Statement attached to this order, completed as required by Rule IvIll I I(-, 64 verification of child care expenses 0) proof of medical coverage which you may have. or may have available to you IP you fill] to appear for the conference or bring the required documents, the Court may issue a %%mrnnt for your arrest. BY THE COURT, George E. Hoffer. President Judge Milli colucsOil Petitioner 10/12/99io: Respondent Emily Long Hoffman. Esquire Kent Patterson. Esquire LX, -17 Daleol'Ordec October 12. 1999 Y R... Shaddav. Conference OtTtcer VOL) HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET I LEGAL IIELP. CUMBERLAND COUNTY BAR ASSOCIATION ?w 2 LIBERTY AVE. CARLISLE. PENNSYLVANIA 17013 (717)249-3166 Y ?.bi?4 ?,, i (`( DAVID L. WILLIAMS Plaintiff V. MELINDA M. ERWAY Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 99-3908 IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW, comes Melinda M. Erway ("Defendant'), by and through her attorney, Emily L. Hoffman, Esquire and Petitions this Court for an award of Alimony Pendente Lite. In support thereof, Defendant represents as follows: I . On July 20, 1999, Defendant filed an Answer to Plaintiffs Divorce Complaint and included a claim for Alimony Pendente Lite. 2. Defendant is requesting a conference/hearing to obtain Alimony Pendente Lite. WHEREAS, Defendant respectfully requests that this Honorable Court grant her Petition for Alimony Pendente Lite. pectfully submitted, Emily Long Hoffman, Esquire Sup. Cl. ID # 66307 105 North Front Street Harrisburg, PA 17108 (717)233-1112 DATED: September 11, 1999 I hereby certify that a true and correct copy of the document was served upon the following person by first class U.S. Mail on this day: Kent Patterson, Esquire 221 Pine Street Harrisburg, PA 17101 Respectfully submitted, By: Emily Long Hoffman, Esquire Sup. Ct. ID t/ 66307 105 North Front Street P.O. Box 11475 Harrisburg, PA 17108 Date: 9/11/99 (717)233-1112 ?? ?? ? F?' ?[ ? ? ?'. -- ? 1 C . ... 1 L? \v DR 28,998 PACSES ID 899101498 DAVID L. WILLIAMS, Plaintiff/Respondent vs. MELINDA M. ERWAY, Defendant/ Petitioner IN TILE COURT Or COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIVIL ACTION - LAW NO. 99-3908 CIVIL TERM ORDER OF COURT AND NOW, this 28'h day of October, 1999, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $2,464.88 per month and Respondent's monthly net income/earning capacity is $4,317.85 per month, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $350.00 a month payable monthly as follows; $350.00 for alimony pendente lite and $0.00 on arrears. First payment due on or before the 13'h day of each month, commencing in November, 1999. Arrears set at $700.00 as of October 27, 1999 and are to be paid, in full, within five days from the date of this order. The effective date of the order is September 13, 1999. Husband is to maintain medical coverage on wife. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S. § 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Melinda Erway. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's PACKS Member Number or Social Security Number in order to be processed. Do not send cash by mail. Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the respondent and 100% by petitioner. The plaintiff is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the Respondent shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of. 1) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. Consented: Plaintiff/Petitioner Defendant/Respondent DRO: R. J. Shadday Mailed _ _ / l ies o Petitioner !-/-q to: : ? Respondent Kent Patterson, Esquire Emily Plon'man, Esquire Plaintiff/Petitioner's Attorney Defendant/Respondent's Attorney BY THE COURT, A?, ) Edgar B. Bayley J. -• m 4 Cl. U F: p u- C.1 NOV 1 1.' 1999 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION MELINDA M. ERWAY, CIVIL ACTION - DIVORCE Plaintiff DOCKET No. 99-3908 CIVIL TERM V. DR No. 28,998 DAVID L. WILLIAMS, Defendant PACES Case Number 899101498 APPEAL AND DEMAND FOR DE NOVO HEARING Date of Order: Mailing Date of Order: Amount: For the support of: Party Failing Demand for Hearing; October 28, 1999 November 1, 1999 $350.00 per month Alimony Pendante Lite Defendant 41?? n K nt H. Patterson Attorney for Defendant 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 Date: November 10, 1999 S_ cr ?_ i.-' L- fi -? _ f'? r ? ?+- ... i`-. ?, -._ _ . .. r- ? EMILY LONG HOFFMAN ATTORNEY AT LAW 105 NORI"H FRONT 57"REET P.O BOX 11475 HARRISBURG, PA 17108-1475 255 MARKET STREET MILLERSBURG, PA 17061 (717) 233-1112 (717) 602-4244 January 25, 2000 rAx(717) 234.2234 e mad: hoffmaneosplw.net E. Robert Elicker, II, Esquire Office of Divorce Master Cumberland County 9 North Hanover Street Carlisle PA 17013 Re: David L. Williams v. Melinda M. Williams Dear Mr. Elicker: Enclosed herewith please find a copy of the form that you requested we submit. Please let me know if I can be of any other service to you. Sinnccerel?y,,, C`-'4 ID Emily Long Hoffman Enclosure cc: Kent Patterson, Esquire a ?y VLv >ti DAVID L. WILLIAMS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99 - 3908 CIVIL MELINDA M. WILLIAMS, Defendant IN DIVORCE TO: Kent H. Patterson Attorney for Plaintiff Emily Long Hoffman Attorney for Defendant DATE: Wednesday, January 12, 2000 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. We require Mr. Williams' current pay information as follows: Copies and all attachments of 1998 and 1999 Income Tax Returns including 1099's and W-2s. Copy of the last pay stub of 1999. Copy of pay stub as of date of marriage and date of separation. Copies of all assets and statements reflecting their values as of the date of marriage and as of the date of separation. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. we will be sending interrogatories and requests for production of documents and anticipate that we will need 120 days to finalize discovery. DATE COUNSEL F. M PLAINTIFF ( ) COUNSEL FOR DEFENDANT (x ) 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. y.h? DAVID L. WILLIAMS, Plaintiff VS. MELINDA M. WILLIAMS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 3908 Civil IN DIVORCE ORDER O OURT AND NOW, this day of 2000, an agreement having been reached between tthrties resolving all claims raised in the proceedings, the agreement, at the request of counsel (see counsel's letter of May 1, 2000, attached hereto), not to be made part of the record, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court, along with the affidavits of consent and waviers of notice of intention to request entry of divorce decree signed by the parties, requesting a final decree in divorce. BY THE COURT, cc: Kent H. Patterson Attorney for Plaintiff Emily Long Hoffman Attorney for Defendant K1 J. i , yr, .,oT1RY ?orfy_,f p;.r3: ?CIV!`?JYLyI: j )U\7Y KENT H.PATTERSON AT"INNEY AT 1.AW 991 PINE STREET IIAREINIIIJEO. PENNAYLVANIA 17101 TELEPHONE 17In Y3"IW May 1, 2000 E. Robert Elicker, II, Esquire Office of Divorce Master Cumberland County 9 North Hanover Street Carlisle, PA 17013 RE: David L. Williams v. Melinda M. Williams No. 99-3908 Dear Mr. Elicker: Please allow this letter to serve as confirmation with your office that the parties have reached a settlement in this case. Although an agreement has been signed, the parties do not want to make the agreement a matter of record at this time. Traci advised me that you will now file the necessary motion or request with the court to have your appointment as Master revoked. I have already filed the consent and waiver forms with the Prothonotary. When I receive the order of court revoking your appointment as Master, I will then file the praecipe to finalize the divorce. Thank you for your consideration. Very truly yours, ! (? 4 Kent H. Patterson KHP/ct cc: Emily Long Hoffman, Attorney at Law hY DAVID L. WILLIAMS, Plaintiff /Respondent V. MELINDA M. ERWAY (WILLIAMS) Defendant/Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : DOMESTIC RELATIONS SECTION : CIVIL ACTION - DIVORCE No. 99-3908 CIVIL DR 28,998 PASCES ID No. 899101498 ORDER OF COURT And now this day of , 2000, upon consideration of the Stipulation of Parties, it is hereby ordered that the appeal filed by Plaintiff /Respondent to the order for alimony pendente lite issued by order of Court dated October 28, 1999 shall be deemed withdrawn, that the order for alimony pendente lite shall be terminated effective April 13, 2000 and that any arrearages shall be canceled. xc: Petitioner Respondent Kent Patterson, Esquire Enlly Lang Hoffman, Esquire (mailed 6-27-00/ds) BY THE COURT: Edgar B. Bayley J. n5 e:aky out"," jay. DAVID L. WILLIAMS, Plaintiff/Respondent V. MELINDA M. ERWAY (WILLIAMS) Defendant/Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION CIVIL ACTION - DIVORCE No. 99-3908 CIVIL TERM DR 28,998 PASCES ID No. 899101498 STIPULATION OF PARTIES And now this 27n day of March, 2000 it is hereby stipulated by David L. Williams, Plaintiff /Respondent, and Melinda M. Erway, Defendant/Petitioner, that the appeal filed by Plaintiff/ Respondent to the order for alimony pendente lite issued by order of Court dated October 28, 1999 shall be deemed withdrawn, that the order for alimony pendants lite shall be terminated effective April 13, 2000 and that any arrearages shall be canceled. Witness: David L. Williams M rv ?,' f? Cn N ? -? a [] 7 C u. r? U c7 U