HomeMy WebLinkAbout99-05798
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF PENNA.
P ??? JY q
PAUL D VE=
Plaintiff
11 No. 99-5798 CIVIL
VERSUS
CHRISTINE M_ VETTF.R
Defendant
DECREE IN
DIVORCE
AND NOWt!n 3 2001 IT IS ORDERED AND
DECREED THAT PAUL D. VE= , PLAINTIFF,
CHRISTINE M. VE=
AND
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; none.
ONOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER, )
Plaintiff )
V. ) NO. 99 - 5798 CIVIL
CHRISTINE M. VETTER, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court for entry of a divorce
decree:
1. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: Service by certified mail on
October 5, 1999; Affidavit of Service filed October 7, 1999.
3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce
Code: by plaintiff, February 10, 2000; by defendant, November 17, 2000.
4. Related claims pending: All claims resolved and withdrawn.
5. Date plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the prothonotary:
February 28, 2000; date defendant's Waiver of Notice in §3301(c) Divorce was filed
with the prothonotary: November 22, 2000.
Date: d.2 SA- dl _
Cindy S. Conley, Esquire
HOWETT, KISSINGER & CO LEY, P.C.
130 Walnut Street
P. O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Paul D. Vetter
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL. D. VETTER,
Plaintiff
V.
CHRISTINE M. VETTER,
Defendant
NO. CIVIL 1094
CIVIL ACTION - LAW
IN DIVORCE
ORDER OF COURT
AND NOW, Q I ? I , 1999, upon consideration of the attached
complaint, it is hereby directed that the parties and their respective counsel appear befog
Y Esquire, the conciliator, at 1'$k_`` ??frr?V?l?1
Pennsylvania, on the 4__ day of *`CKmkr C, 1999, at o'clock
(A m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to
resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to
be heard by the court, and to enter into a temporary order. Either party may bring the child who
is the subject of this custody action 2r o die c"onf&nce, but the child's attendance is not mandatory.
Failure to appear at the conference may provide grounds for entry of a temporary or permanent
order.
FOR THE COURT,
By:6 P?-164
Custody Conciliator t ?>
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.
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 240-6200
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER,
Plaintiff )
V. ) NO. CIVIL 1999
CHRISTINE M. VETTER, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree of divorce or annulment may be entered against you by
the court. A judgment may also be entered against you for any other claim or 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 divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of manage counselors is available in the Office of
the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania
17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER, )
Plaintiff )
V. ) NO. I CIVIL 1999
CHRISTINE M. VETTER, )
CIVIL ACTION -LAW
Defendant ) IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes Plaintiff, Paul D. Vetter, by and through his counsel, Howett,
Kissinger & Conley, P.C., who states the following in support of the within Complaint:
1. Plaintiff is Paul D. Vetter, an adult individual who currently resides at 4
Richland Lane, Apartment T-1, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. Defendant is Christine M. Vetter, an adult individual who currently resides
at 412 S. Market Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
3. Both the Plaintiff and the Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for a period of at least six (6) months immediately preceding
the filing of this Complaint.
4. Plaintiff and Defendant were married by common law.
5. Neither Plaintiff nor Defendant is in the military or naval service of the
United States of its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of
the Congress of 1940 and its amendments.
6. There have been no prior actions for divorce or annulment of the marriage
instituted by either of the parties in this or any other jurisdiction.
7. Plaintiff has been advised that counseling is available and that Plaintiff
may have the right to requcst that the Court require the parties to participate in counseling.
8. The marriage of the parties is irretrievably broken.
9. The parties have lived separate and apart since in or about August 1998.
10. Plaintiff requests the court to enter a decree of divorce.
It. The parties are the parents of the following child who resides with
Defendant and her boyfriend, Dustin:
Name
Maxinne M. Vetter
Date of Birth
September 17, 1992
12. During the past five years, the child has resided with the parties and at the
addresses herein indicated:
Dates With Whom Addresses
May to Present Defendant and 412 S. Market Street
boyfriend, Dustin Mechanicsburg, PA 17055
May 1996 to May 1999 Defendant 2151 Queens Drive
Camelot Village Apartments
Harrisburg, PA
Prior to May 1996 Plaintiff and 2151 Queens Drive
Defendant Camelot Village Apartments
Harrisburg, PA
13. Plaintiff has not participated in any other litigation concerning the child in
this or any other state.
14. There are no other proceedings pending involving custody of the child in
this or in any other state.
15. Plaintiff knows of no person not a party to these proceedings who has
physical custody of the child or who claims to have custody, partial custody or visitation rights
with respect to the child.
16. Sole custody isolates the child from the non-custodial parent.
17. The best interests of the child require that open and meaningful access be
maintained with each parent and that she have a relationship with each parent.
18. The child has developed emotional attachment to each parent and the
severing of either attachment is not in the child's best interest.
19. Permitting each parent to remain involved in the life of the child enables
the child to share with each parent the intimate contact necessary to strengthen a true parent-child
relationship.
WHEREFORE, Plaintiff respectfully requests that the Court enter an order awarding him
shared legal custody and partial physical custody of the child.
Date: 1-
Respectfidly submitted,
Cindy S. Conley squire
HOWETT, K[ SINGER & CO Y, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff
Paul D. Vetter
VERIFICATION
I, Paul D. Vetter, hereby swear and affirm that the facts contained in the foregoing
Complaint in Divorce are true and correct to the best of my knowledge, information and belief
and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to
authorities.
Date: 9
Paul D. Vetter
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HOWETT, KISSINCER & CONLEY, P.C.
1.30 WALNUI'STRF.E:T ,
POST OFFICE BOX 810
Ilexxmuvxa, PLNX\y(I'ANIA 17108
SEA' ? i 199
PAUL D. VETTER
Plaintiff
V.
CHRISTINE M. VETTER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99.5798
CIVIL ACTION - LAW
DIVORCE/CUSTODY
I, Deborah R. Clark, hereby certify that a true and correct copy of a Petition
For Related Claims Under The Divorce Code, in the above captioned matter, was duly
served upon Cindy S. Conley. Esq., counsel for the Plaintiff, by depositing it in the
U.S. Mail, overnight delivery, on March 7, 2000, addressed as follows:
Cindy S. Conley, Esq.
HOWETT, KISSINGER & CONLEY, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
I hereby verify that the statements made in the foregoing 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 unsworn falsification to authorities.
Dated: March 7, 2000
Deborah R. Clark
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER,
Plaintiff
V.
CHRISTINE M. VETTER,
Defendant
NO. 99 - 5798 CIVIL.
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF COUNSELING
A complaint in divorce under §3301(c) of the Divorce Code was filed on
September 20, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety
days have elapsed from the date of filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to
unworn falsification to authorities.
Date: D vuo /'
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Paul D. Vetter, Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER,
Plaintiff
V.
CHRISTINE M. VETTER,
Defendant
NO. 99 - 5798 CIVIL
CIVIL ACTION - LAW
IN 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. §4904
relating to unswom falsification to authorities.
Date: O
Paul D. Vet er, Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER,
Plaintiff )
V. ) NO. 99 - 5798 CIVIL
CHRISTINE M. VETTER, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
A complaint in divorce under §3301(c) of the Divorce Code was filed on
September 20, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety
days have elapsed from the date of filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of notice of
intention to request entry of the decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by
the Court and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904
relating to unswom falsification to authorities.
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Date: f Cam) 0I'll /of
Christine M. Vetter, Defendant
PAUL D. VETTER,
Plaintiff
Vs.
CHRISTINE M. VETTER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
. NO. 99 - 5798 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this IS ? day of
i
2001, the Master having been advised that the issues in the
above captioned divorce proceedings have been settled and
that economic claims raised by the Defendant have been
withdrawn, 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,
cc: Paul D. Vetter
Plaintiff
Cindy S. Conley
Attorney for Defendant
Georg Hoffer, P. .
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PAUL D. VETTER
Plaintiff
V.
CHRISTINE M. VETTER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5798
CIVIL ACTION - LAW
DIVORCE/CUSTODY
ORDER OF COURT
AND NOW this 2100, day of November, 2000, upon cc isideration of counsel's
Petition to Withdraw Appearance for Christine M. Vetter, it is hereby ORDERED and DECREED
that counsel, Andrea C. Jacobsen, Esq., for JACOBSEN & MILKES, is granted leave to
withdraw her appearance in this matter as counsel for defendant, Christine M. Vetter.
BY THE CO
J.
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PAUL D. VETTER : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-5798
CHRISTINE M. VETTER, : CIVIL ACTION - LAW
Defendant : DIVORCEICUSTODY
PETITION OF COUNSEL
TO WITHDRAW APPEARANCE FOR CHRISTINE M. VETTER
JACOBSEN & MILKES, by Andrea C. Jacobsen, Esquire, hereby respectfully petitions
this Court for leave to withdraw their appearance as counsel for defendant, Christine M. Vetter,
and, in support thereof, aver as follows:
1. Petitioner is Andrea C. Jacobsen, Esquire, on behalf of JACOBSEN & MILKES.
2. Respondent is Christine M. Vetter, defendant herein.
3. Petitioner was retained by respondent on or about October 18, 1999, to
represent her in the above captioned divorce matter.
4. Respondent has advised counsel that she wishes to proceed at this time without
representation. A copy of her written direction to counsel is set forth as Exhibit A.
5. Cindy S. Conley, Esq., HOWETT, KISSINGER & CONLEY, P.C., counsel for
plaintiff, Paul D. Vetter, concurs in this petition.
WHEREFORE, Petitioner, Andrea C. Jacobsen, Esquire, respectfully request
leave to withdraw her appearance as attorney for defendant.
Renspectfull milted,
BY: An rea C. acobsen
JACOB MILKES
52 E. High Street
Carlisle, PA 17013
(717) 249-6427
(717) 249-8427 - Fax
Attorney No. 20952
Christine Vetter
412 S. Market Street
Mechanicsburg, PA 17055
(717) 691-7232
11/9/2000
To whom it may concern,
Np`
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I do not wish to be represented by legal counsel in my divorce situation with Paul Vetter.
I have decided that I do not want to contest the divorce. I want to drop any current issues
that were originally brought up during the last attempt to finalize the divorce. I have no
financial or property concerns related to this situation and I would like to have this
divorce finalized. I am available to sign any documentation necessary to help facilitate
this process. I can be contacted at the above number to confirm the information in this
letter. Thank you for your time and consideration in this matter
Sincerely,
Christine Vetter
P.S. Dear Mrs. Jacobsen: I want to thank you for your past representation in reference to
the above matter. I have decided that I do not wish to contest this divorce and therefore it
is not necessary for me to retain legal counsel. Paul Vetter's attorney will also receive a
copy of this letter. If you have any questions or concerns please feel free to contact me.
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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
TO: The Honorable George E. Hoffer, President Judge
FROM: E. Robert Elicker, 11, Divorce Master
DATE: Thursday, January 18, 2001
RE: Vetter vs. Vetter
No. 99 - 5798 Civil
West: Shore
697-0371 Ext. 6535
No agreement is attached inasmuch as the letter from counsel dated January 8, 2001,
which is attached, indicates that the claims have been settled but that no marital
settlement agreement has been executed.
LAw Onw u w
HOWErF, KISSINGER & CONLEY, P.C.
130 WALNUT STREET
POST OFFICE BOX 810
Hmtasss o,P0mnvAwu 17108
JOIINC. HOWETT,IR.
DONALD T. KISSINGER
CINDY S. CONLEY
DARREN J. HOLST
DEBRA M. SHIMP
Lege1 Assistant January 8, 2001
E. Robert Elicker, II, Esquire
Office of the Divorce Master
9 Nolth Hanover Street
Carlisle, PA 17013
Re: Vetter v. Vetter
Docket No. 99-5798
Dear Mr. Elicker:
(717) 234-2616
FAX (717) 234.5102
We would like to proceed with the finalization of the above-referenced
divorce action. Enclosed please find time-stamped copies of Affidavits of
Consent and Waivers of Notice for both parties as well as a time-stamped copy of
the Praecipe Withdrawing Ancillary Claims as executed by Christine Vetter. Also
enclosed is a copy of Judge Guido's November 27, 2000 Order of Court granting
Attorney Jacobsen leave to withdraw her appearance on behalf of Christine
Vetter. While the parties did not execute a Marital Settlement Agreement, this
case is, in fact, settled, and we would like to proceed to entry of a final divorce
decree.
If you have any questions or require further documentation, please call my
legal assistant, Deb Shimp. Thank you for your assistance with this matter.
Very truly yours,
Cindy S. Conley
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Enclosures
cc: Paul D. Vetter
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PAUL D.VETTER, NO.+Ii?iYI?? CIVIL 19
Plaintiff !!!///
VS.
CHRISTINE M.VETTER,
Defendant
IN DIVORCE
STATUS SHEET
DATE:
1/19,00 ACTIVITIES:
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PAUL D. VETTER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 5798 CIVIL
CHRISTINE M. VETTER,
Defendant IN DIVORCE
TO: Cindy S. Conley Attorney for Plaintiff
Andrea C. Jacobsen Attorney for Defendant
DATE: Monday, June 19, 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.
L-
(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
West Shore
697-0371 Ext. 6535
October 23, 2000
Cindy S. Conley
Attorney at Law
HOWETT, KISSINGER & CONLEY, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Andrea C. Jacobsen
Attorney at Law
JACOBSEN & MILKES
52 East High Street
Carlisle, PA 17013
RE: Paul D. Vetter vs. Christine M. Vetter
No. 99 - 5798 Civil
In Divorce
Dear Ms. Conley and Ms. Jacobsen:
Ms. Conley returned the certification document on July 7, 2000,
indicating that discovery is complete. Attorney Jacobsen has not returned
the certification document but I am going to proceed on the basis that
there are no issues requiring further discovery and that the case can move
forward to trial.
A divorce complaint was filed on September 20,1999, raising grounds
for divorce of irretrievable breakdown of the marriage. The complaint also
averred that the parties were married by common law in Paragraph 4. If
there is a dispute as to whether or not there is a common law marriage,
please advise so we can schedule a hearing on that issue immediately.
Ms. Conley and Ms. Jacobsen, Attorneys at Law
23 October 2000
Page 2
On March 9, 2000, the Defendant filed a petition raising the claims of i.
equitable distribution and counsel fees and expenses. On June 5, 2000, the
Plaintiff filed a petition raising a claim for counsel fees, expenses, and costs.
I am going to proceed on the assumption that grounds for divorce are
not an issue and further that there is no issue with regard to the marital
status of the parties. As previously noted, if there is a question about
whether or not the parties have entered into a common law marriage, we
should be advised and we will schedule a hearing on that issue first.
Assuming that there is no issue on the status of the marriage or grounds for
divorce, I am going to issue a directive for the filing of pretrial statements.
In accordance with P.R.C.P. 1920.33(b) I am directing each counsel to
file a pretrial statement on or before Friday, November 17, 2000. Upon
receipt of the pretrial statements, I will immediately schedule a pre-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.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER,
Plaintiff )
V. ) NO. 99 - 5798 CIVIL
CHRISTINE M. VETTER, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
PETITION RAISING MARITAL CLAIMS
AND NOW, comes Plaintiff, Paul D. Vetter, by and through her counsel, Howett,
Kissinger and Conley, P.C., and files this Petition Raising Marital Claims and in support thereof
states as follows:
Plaintiff is Paul D. Vetter, an adult individual who currently resides at
4 Richland Lane, Apartment T-1, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. Defendant is Christine M. Vetter, an adult individual who currently resides
at 412 South Market Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
3. Plaintiff and Defendant were married by common law.
4. A Complaint for Divorce was filed by Plaintiff on September 20, 1999 in
Cumberland County, Pennsylvania.
5. Plaintiff hereby raises the following marital claims:
COUNT I - COUNSEL FEES. EXPENSES AND COSTS OF SUIT
6. The foregoing paragraphs of this Petition are incorporated herein as if set
forth at length.
7. Plaintiff has retained an attorney to defend him in this action and has
agreed to pay her a reasonable fee.
8. Plaintiff has incurred and will incur costs and expenses in defending this
action.
9. Plaintiff is not financially able to meet either the expenses and costs of
defending this action or the fees to which his attorney will be entitled in this case.
WHEREFORE, Plaintiff requests the Court to enter an award of interim counsel fees,
costs and expenses until final hearing and thereupon award such additional counsel fees, costs
and expenses as deemed appropriate.
Date: _6 :?-a
Respectfully submitted,
Cindy S. Con squire
HOWETT,1 SSINGER & C LEY, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Paul D. Vetter
VERIFICATION
I, Paul D. Vetter, hereby swear and affirm that the facts contained in the foregoing
Petition Raising Marital Claims are true and correct to the best of my knowledge, information
and belief and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom
falsification to authorities.
Date:
aul D. et r
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PAUL D. VETTER : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 99-5798
CHRISTINE M. VETTER, : CIVIL ACTION - LAW
Defendant : DiVORCE/CUSTODY
PETITION FOR RELATED CLAIMS UNDER THE DIVORCE CODE
AND NOW COMES Petitioner Christine M. Vetter, Defendant in the above
captioned matter and asserts against Respondent/Plaintiff, Paul D. Vetter, the
following claims for relief in this matter under Section 3301 of the Divorce Code:
EQUITABLE DISTRIBUTION
1. During their marriage, the parties acquired property which property
is marital property.
2. During their marriage, the parties incurred debt which is marital
debt.
3. Plaintiff and Defendant have not agreed as to an equitable division
of the marital property and debt.
COUNSEL FEES, COSTS AND EXPENSES
4. Defendant incorporates herein by reference the prior paragraphs.
5. Defendant has hired counsel but due to her limited income and
resources is unable to support herself and pay necessary and reasonable
attorney's fees of counsel and the costs and expenses of defending her rights and
litigating her claims in this action.
6. Defendant requests the Court to enter an award of reasonable
counsel fees, costs and expenses.
WHEREFORE, the Defendant respectfully requests that this Court:
a. equitably distribute the marital property and marital debt between the
parties;
b. direct the Plaintiff to pay Defendant reasonable counsel fees and costs in
order to allow Defendant to protect her interests in this case;
c. grant such further relief as the Court may deem proper and just.
Respectfully submitted,
Cis ? .
---------- --- ---------
BY: Andr a . Jacobsen
52 E. Hig reet
Carlisle, PA 17013
(717) 249-6427
(717) 249-8427 - Fax
Attorney No. 20952
Attorney for Defendant
I hereby verify that the statements made in the foregoing are true and
correct. I understand that false statements uere;n we made subject to the
penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to
authorities.
Dated: ta?t?,,_
CHRISTINE M: VETTER '?
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P1 THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSTLVANIA
PAUL D. VE17ER
VS.
Plaintiff
CHRISTINE M. VETTER
NO. 99-5798
••••• - iriaintizrl moves the court to appoint
a master with respect to the following claims:
( X) Divorce ( X) Distribution of Property
( ) Annulment ( ) Support
( ) Alimony ( X) Counsel Fees
( ) Alimony Pendente Lite ( X) Costs and Expenses
and in support of the motion states:
Yollowing claims:
distribution ofc) The action is contested with respect to the followin
claims: property, counsel fees, costs and expenses
(5) The action (fh?65YVexs) (does not involve) complex issues o
or fact.
(1) Discovery is complete as to the claims(s) for which the
appointment of a master is requested.
(2) The defendant (has) (kan:6xXVC0 appeared in the action (pemm )
(by his attorney, Andrea C. Jacobsen Esquire).
(3) The staturory ground(s) for divorce (is) (are) 3301(c)
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
(6) The hearing is one
expected to take (i13) (days) .
(7) Additional information, if any. relevant to the motion:
Date: June 1. 2000
AND NOW a ??? }g
is appointed master with respect to
Attorney
(DmmafflS)
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placed. ? n ?I?cKe?s ?? I?
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PAUL D. VETTER,
Plaintiff
VS.
CHRISTINE M. VETTER,
Defendant
TO: Cindy S. Conley
Andrea C. Jacobsen
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 5798 CIVIL
IN DIVORCE
Attorney for Plaintiff
, Attorney for Defendant
DATE: Monday, June 19, 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.
J
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
Q"tA a R? , /Ja cut ,
7" V DATE COU L FOR P I TI F
COUNSEL FOR EFENDANT
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.
Samuel W. Milkes
Andrea C. Jacobsen
JACOBSEN & MILKES
52 East High Street
Carlisle, PA 17013-3085
June 20, 2000
Mr. E. Robert Elicker, II
Office of Divorce Master
Cumberland County
Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
RE: Paul D. Vetter u. Christine M Vetter
No. 99-5798
In Divorce
Dear Mr. Elicker:
Tel 717-249-6427
Fax 717-249-8427
We are in receipt of the Certification on the above referenced matter.
Ms. Jacobsen is currently out of the Country and will not be back in the office
until July 24, 2000. When she returns to the office I will have her review this
information and return it to your office in a timely manner.
Thank you.
Sincerely,
DAD/
(corn) 0620 E lic ke r. ve t
Dana A. Dunkle
Legal Assistant
LAW OFFICES OF
IIOWETT, KISSINGER & CONLEY, P.C.
130 WALNUT STREET
POST OFFICE BOX 810
HARRISBURG, PENNSYLVANIA 17108
TO: Robert E. Elicker, II, Divorce Master
9 N. Hanover Street
Carlisle, PA 17013
DATE: July',, 2000
RE: Vetter v. Vetter
We enclose the following to keep you informed of the progress of this matter:
A Certificate of Discovery.
For your review/records
? For your signature
? Kindly return
? Please call upon receipt
? Per your request
? Call for an appointment
Please call us if you have any questions.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER, )
Plaintiff )
V. ) NO. 99 - 5798 CIVIL
CHRISTINE M. VETTER, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
AFFIDAVIT OF SERVICE
Cindy S. Conley, being duly swom according to law, deposes and says that she is an
attorney at law authorized to practice in the Commonwealth of Pennsylvania, and that on the
4a' day of October, 1999, she sent the original of the attached letter, with which was enclosed a
certified, time-stamped copy of the Complaint in Divorce in the above-captioned matter, properly
endorsed, to the Defendant, Christine M. Vetter, by certified mail, postage prepaid, return receipt
requested, restricted delivery, pursuant to Pa.R.C.P. 1930.4, to 412 South Market Street,
Mechanicsburg, PA, 17055, the Defendant's last known address, and that the return receipt card
which was signed by C. M. Vetter, marked as having been delivered to her on October 5, 1999, is
attached hereto and made a part hereof.
C
Cindy S. Conlo, Esquire
HOWETT, KISSINGER ONLEY, P.C.
130 Walnut Street
P. 0. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
SWORN TO AND SUBSCRIBED
6th day October, 1999.
DEBRA M. SHIMP, Notary
Harrisburg, Dauphin Coun
Lew OIIICU OF
HOWETT, KISSINGER & CONLEY, P.C.
170 WALNVr STREET
POST OFFICE BOX 810
Hu seuio. Pv snve 17108
JOHN C. HOWETT
DONALD T. KISSINGER
CINDY S. CONLEY
DEBRA M. SHIMP,
LeS&I A» isms October 4, 1999
CERTIFIED MAIL
RESTRICTED DELIVERY
Ms. Christine M. Vetter
412 South Market Street
Mechanicsburg, PA 17055
Re: Vetter v. Vetter
Dear Ms. Vetter:
(7171'-74.2616
FAX (717):74-5402
Enclosed please find a Complaint in Divorce which includes a Custody
Count as well as a Certified Order of Court scheduling a custody conciliation for
November 4, 1999 at 11:00 a.m. at 302 South 18" Street, Camp Hill,
Pennsylvania. Please take this document to an attorney. Please have your
attorney contact me so that we can discuss an amicable settlement to the custody
as well as other issues raised in this divorce complaint.
Very truly yours,
Cindy . Conl
CSC/dik
Enclosure
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PAUL D. VETTER
Plaintiff
V.
CHRISTINE M. VETTER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99.5798
CIVIL ACTION - LAW
DIVORCE/CUSTODY
PRAECIPE FOR ENTRY OF APPEARANCE
Please enter my appearance for the Defendant in the above referenced
matter.
Respectfully submitted,
i ?KSIt?M?ter 2 ? 1y??S ? )2?C
I BY: Andre C. Ja sen
JACOBSE &741ILKES
52 E. High Street
Carlisle, PA 17013
(717) 249.6427
(717) 249-8427 - Fax
Attorney No. 20952
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PAUL D. VETTER, ) IN THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS. )
NO. 99-5798 CIVIL
CHRISTINE M. VETTER, )
Defendant ) CIVIL ACTION - LAW
IN DIVORCE
ORDER
AND NOW, this day of P i?? , 1999, upon receipt of the
Conciliator's Report, it appearing that the parties have agreed to the terms and provisions of this
Order which was dictated in their presence and approved by them and their counsel, it is hereby
ordered and directed as follows:
I. The parties shall share legal custody of the minor child, Maxinne M.
Vetter, d.o.b. September 17, 1992.
2. Mother shall have primary physical custody of the minor child subject
to periods of partial custody and visitation with Father as follows:
A. During the school year, Father shall have the child on
alternating weekends from Friday at 6:30 p.m. until Monday
morning at which time Father will drop the child off at school or
the appropriate day care provider, in case school is not in session.
B. On alternating "Thursdays, those Thursdays to occur
following his alternating weekend schedule from after school until
the following morning at which time Father will drop the child off
at school or the appropriate day care provider, in case school is not
in session. Father is also to provide the transportation when
picking up the child after school.
C. During the summer months, the parties shall alternate
custody of the child on a week-on, week-off basis, the switch day
to be Friday at 6:30 p.m. This alternating week schedule shall
commence with the first Friday after the child is released from
school. The schedule shall commence with Mother having the first
full week. Additionally, if Father is not off from work and Mother
is otherwise available, Father shall use Mother as the daycare
provider during the summer months. Additionally, if Father's
work schedule prevents him from getting the child prior to 8:30
p.m., then Father will agree that the child will stay overnight at the
Mother's residence. The parties also will try to accommodate each
other in the event that they have a vacation scheduled that will
cause their periods of time while on vacation to run over into the
alternate week.
3. The parties shall share the Thanksgiving holiday each year. Father
shall have the child from 9:00 a.m. until 4:00 p.m., and Mother shall have the
child from 4:00 p.m. for the remainder of that day.
4. Mother shall have a minimum of three (3) hours with the child each
Easter.
5. The parties shall alternate the following holidays: New Year's (the
New Year's holiday is defined from New Year's Eve at 4:00 p.m. until New
Year's Day at 4:00 p.m.), Memorial Day and Labor Day. The Memorial Day and
Labor Day schedule shall be from 9:00 a.m. until 8:00 p.m. This alternating
schedule shall commence with Father having New Year's in 1999, and the
schedule shall alternate thereafter.
6. The Christmas holiday shall be broken into two segments. Segment A
shall be from Christmas Eve at 12:00 noon until Christmas Day at 12:00 noon;
Segment B shall be from Christmas Day at 12:00 noon until December 26m at
12:00 noon. Mother shall have Segment A in 1999 and all odd years thereafter
and Segment B in 2000 and all even years thereafter. Father shall have Segment
B in 1999 and all odd years thereafter and Segment A in 2000 and all even years
thereafter.
7. Mother shall have the child on Mother's Day and Father shall have the
child on Father's Day. These periods of partial custody and visitation shall be
from 9:00 a.m. until 8:00 p.m.
8. Such other times as the parties may agree.
BY THE COU
J.
Cindy S. Conley, Esquire _ rxa?f.A It ?lre X49,
Andrea Jacobsen, Esquire g (?
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PAUL D. VETTER,
Plaintiff )
VS. )
CHRISTINE M. VETTER, )
Defendant )
JUDGE PREVIOUSLY ASSIGNED: None
CUSTODY CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report:
I. The pertinent information concerning the child(ren) who is(are) the subject of this
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 99-5798 CIVIL
CIVIL ACTION -LAW
IN DIVORCE
litigation is as follows:
NAME
BIRTHDATE
CURRENTLYIN
CUSTODY OF
Maxinne M. Vetter
September 17, 1992
Defendant
2. A Conciliation Conference was held on November 4, 1999, and the following
individuals were present: the Plaintiff and his attorney, Cindy S. Conley, Esquire; the Defendant
and her attorney, Andrea Jacobsen, Esquire.
3. Items resolved by agreement: See attached Order.
4. Issues yet to be resolved: See attached Order.
5. The Plaintiffs position on custody is as follows: See attached Order.
6. The Defendant's position on custody is as follows: See attached Order.
7. Need for separate counsel to represent child(ren): Neither party requested.
8. Need for independent psychological evaluation or counseling: None requested and the
Conciliator does not believe any is necessary.
Date: November 10, 1999
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER,
Plaintiff
v.
CHRISTINE M. VETTER,
Defendant
AND NOW this 64*
NO. 99-5798
CIVIL ACTION - LAW
DIVORCE/CUSTODY
ORDER OF COURT
day of t I'?? , 2000, it is hereby
ORDERED and DECREED that the attached Amendment to Custody Order of November 15,
1999 is hereby entered as an Order of this Court.
BY THE CO T:
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Parties agree that their custody order of 11/15/99 shall be
amended to add the following:
During the winter schedule, father shall have the child:
• Every Thursday and Friday
• Every other weekend
Both Thursday and Friday are to be full days. A full day means
that if there is no school then the father has child the entire day.
Father will pick child up on Thursday at 3:30pm on school days
and 9:00am on non-school days. Father will return child on
Saturday at 9:00am unless it is his weekend.
I Christine Vetter agree to the above stipulations and
wish toAavQ them incoroorated into an orde f
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Datad
I Paul Vetter agree to the above stipulations and wish to
have them incorporateshnto an order of court.
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LAW OFFICES OF
HOWETT, KISSINGER & CONLEY, P.C.
130 WALNUT STREET
POST OFFICE BOX 810 „ U 2M
HA,txiSnuxa, PENNSYLVANIA 17108 ,
JOHN C. HOWETT, JR.
DONALD T. KISSINGER
CINDY S. CONLEY
DARREN J. HOLST
DEBRA M. SHIMP
Lepi Assistant
E. Robert Elicker, 11
Divorce Master
9 N. Hanover Street
Carlisle, PA 17013
November 16, 2000
Re: Vetter v. Vetter
Docket No. 99-5798
Dear Mr. Elicker:
(717) 234-2616
FAX (717) 234.3402
I represent Paul Vetter in the above-referenced case. Be advised that 1 have been notified
directly by Mrs. Vetter that she is no longer represented by Andrea Jacobsen, Esquire, and that
she wishes to withdraw her ancillary economic claims and proceed to the entry of a final divorce
decree on or after January 1, 2001. Accordingly, I have forwarded to her the necessary
documents for her signature to accomplish the above which is likewise agreeable to Mr. Vetter. I
note that pursuant to your pretrial order, pretrial statements are due on behalf of both parties on
Friday, November 17, 2000. As it appears as though the parties have reached an agreement in
regard to all outstanding issues, I would ask that the pretrial statement due date be continued
generally. Upon receipt of the executed documents necessary to finalize the divorce on or after
January 1, 2001, from Mrs. Vetter, I will notify your office and vacate your appointment as
master. If I need to take any further action, please do not hesitate to contact me.
Thank you for your assistance in this matter.
Very truly yours,
CSC/djk
cc: Andrea C. Jacobsen, Esquire
LAw Ovncss of
HOWETT, KISSINGER & CONLEY, P.C.
130 WALNUT STREET
POST OFFICE Box 810
HUMS=. Pt nvasnn 17108
Cindy S. Conley'
Paul D. Vetter
Christine Vetter
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER,
V.
Plaintiff
NO. 99 - 5798 CIVIL
CHRISTINE M. VETTER,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE WITHDRAWING ANCILLARY CLAIMS
TO THE PROTHONOTARY:
Please withdraw the ancillary claims raised in my Petition for Related Claims Under the
Divorce Code filed with this Court on or about February 27, 2000.
Date: 4/"
Christine M. er, Defendant
PAUL D. VETTER IN TI Its C'OURTOP COMMON PLEAS OF
PLAIN'IIFF ('1IMBIiR1,AND COON-I'Y, PENNSYLVANIA
V.
99-5798 CIVIL ACTION LAW
CHRISTINE M. VETTER
DEFENDANT
IN CUSTODY
ORDER OF COI; RT
AND NOW, Tuesday, December 23, 2003 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before __ Dawn S. Sunday, Esq. , the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, January 20, 2004 at 10:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR TI IE COURT.
By: A/ Dawn S. Sunday, Esq, L/
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business- befirre the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SI IOULD TAKE •I'ITIS PAPER TO YOUR ATT'ORNE'Y AT ONCE. IP YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WIIERE YOU CAN GET LE(iAl. HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
zP3 ?-)3
DEC 19 2003
IN THE COURT OF COMMON PLEAS OF THE 9th JUDICIAL
DISTRICT CUMBERLAND COUNTY, PENNSYLVANIA
PAUL D. VETTER
Plaintiff/ Petitioner
V.
CHRISTINE M. VETTER
Defendant/ Respondent
No. 99-5798
Civil Action-Petition to
Modify Child Custody
ORDER
AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties
and their respective counsel appear before the Custody Conciliator
Esquire, on the day of 2004 at
.in. at the following location,
for a Pre-Hearing Custody Conference. At such Conference, an
effort will be made to resolve the issues in dispute; or if this cannot be accomplished , to define and
narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age
five or older may also be present at the Conference upon request of either parry. Failure to appear
at the Conference may provide grounds for entry of a temporary or permanent Order.
Date:
FOR THE COURT
Custody Conference Officer
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
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
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
PAUL D. VETTER
Plaintiff/ Petitioner
No. 99-5798
V.
CHRISTINE M. VETTER
Defendant/ Respondent
Civil Action-Petition to
Modify Child Custody
PETITION TO MODIFY CHILD CUSTODY
1. Petitioner is Paul D. Vetter, Plaintiff in the underlying action who resides at 4
Richland Lane, Apt 101, City of Camp Hill, County of Cumberland, Commonwealth
of Pennsylvania 17034. Petitioner is represented by Lee E. Oesterling, Esquire, 42
East Main Street, 17011.
2. Respondent is Christine M. Vetter, Defendant in the underlying action who resides at
412 South Market Street, City of Mechanicsburg, County of Cumberland,
Commonwealth of Pennsylvania 17055.
3. The parties are the natural parents of Maxinne M. Vetter, bom September 17, 1992,
(hereinafter referred to as the "Child").
4. On November 15'h 1999, an Order of Court was entered and was subsequently
modified by further Order of Court dated November 6`h 2000
5. Since the entry of said Order, there has been a significant change in circumstances for
the following reasons as hereinafter outlined.
(a) Petitioner spends substantial time in taking care of his daughter to the extent
that the extant Custody Order does not reflect the actual custodial
arrangement.
(b) Petitioner believes that the best interests of the child will be served by a
modification of the existing Order of Court as this would allow for
consideration of the child's longer term needs.
6. The Court in modifying said Order for the aforementioned reasons will serve the best
interest of the child.
WHEREFORE, petitioner prays this Court to grant the modification of the existing
Custody Order to allow him primary custody of the parties' child.
Respect lly submitted,
"IX
Lei E. Oeste ng, squire
Supreme Court I.D. #71320
42 East Main Street
Mechanicsburg, PA. 17055
(717) 790-5400
I verify that upon personal knowledge or information and belief that the statements made in this
Petition 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.
aul Vette
Date: o a 3
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JUN 0 004
PAUL D. VETTER IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
99-5798 CIVIL ACTION LAW
CHRISTINE M. VETTER
Defendant IN CUSTODY
ORDER
AND NOW, this 22nd day of June, 2004 , the conciliator, having received no request
from counsel for either party to schedule a follow-up conference to conclude the January 20, 2004
conference terminated due to counsel's time constraints, hereby relinquishes jurisdiction.
FOR THE COURT,
Dawn S. Sunday, Esquire
Custody Conciliator
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