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HomeMy WebLinkAbout03-3605 JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 03 - 3605, Civil Term LYNN S. BLAUCH, DEFENDANT In Divorce ORDER APPOINTING MASTER < And Now, :4b1-u~? .200L [!~~ Esquire, is appointed master with respect to the claims of distribution of property, counsel fees, and costs and expenses. BY THE COURT: /1. Distribution: William M. Shreve, 3618 North Sixth Street, Harrisburg, PA 17110 Lynn Blauch, Defendant, 312 Okisco Trail, Edenton, N.C. 27932 \It.:!vr:;} 5;i-,1: ~.:>j I 'I,'n~" -"""n" ^J.. '>\, t\..',) '~";"\' v L1"J:\ ~ld 9- 9Jj~Ufil m~lOt,OH10dd 3\-\1 .::lO 38\:!:<<Xi31\:! ~ JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 03 - 3605, Civil Term LYNN S. BLAUCH, DEFENDANT In Divorce MOTION FOR APPOINTMENT OF MASTER Jeffrey L. Blauch, Plaintiff, respectfully moves Your Honorable Court to appoint a master with respect to the pending divorce for the purpose of establishing an equitable distribution of property, counsel fees, and costs and expenses and in support thereof, states the following: 1. It is believed that discovery is not needed for claim for which the appointment of a master is needed. 2. The defendant has not appeared in the action personally but has received notice of the proceeding. 3. The statutory ground for dissolution of the marriage is irretrievable breakdown. 4. The action is contested with respect to the distribution of property. 5. The action does not involve complex issues of law or fact. 6. A hearing is expected to take 2.5 hours. 7. The defendant is currently in possession of the marital home located at 312 Okisko Trail, Edenton, North Carolina, and a marital vehicle, a 2000 Ford Van. 8. The defendant is in possession of the following personal items belonging to the plaintiff that have been requested to be returned. 1. Black leather jacket; 2. Black suede jacket; 3. Black oiled motorcycle duster; 4. Black leather vest; 5. Black leather chaps; 6. Harley Davidson boots; 7. Entire wardrobe consisting of: a. 10 suits b. 20 pair of dress pants c. 10 pair of casual pants d. 30 dress shirts e. 10 casual shirts f. 5 pair of jeans g. shorts and summary shirts h. 6 pair shoes, including imported Italian shoes. 8. Motorcycle helmets; 9. Set of keys to motorcycle; 10. Titles to truck and motorcycle; 11. 20 DVD movies; 12.30+ CDs and rack; 13. Picture of grandparents' 50th anniversary; 14. Jeff's yearbook; 15. Coin collection; 16. Sony Mavica digital camera; 17. Camcorder; 18. Lionel 0 gauge passenger train; 19. Lionel G scale trains; 20. Train from plaintiff's mother; 21. Tractor toy received from grandparents; 22. Clock radio received from grandparents; 23. Green Radio received from grandparents; 24. 2 collectible knives; 25. Antique recliner; 26. Jeff's mother's vanity; 27. Antique sewing machine received from grandparents; 28. Woodworking tools; 29. Lathe and lathe tools; 30. Computer software and tools; 31. Jewelry, including 2 chains, 1 bracelet imported from Italy; 32. Gold-rimmed glassware imported from Italy; 33. Various LP albums; 34. Red briefcase with military record; 35. Electrolux vacuum; WHEREFORE, For the foregoing reasons, plaintiff respectfully requests that a Master be appointed in this matter. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 9 4904, relating to unsworn falsification to authorities. Date: //).. v;09' (J.R_)('Uc! &0U4{~. :4reA~h, Plaintiff ~#- William M. Shreve Attorney for Plaintiff 10 # 82337 (717) 234-6001 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 CERTIFICATE OF SERVICE AND NOW, this _4th day of February, 2004, I, Dawn E. Minori, Secretary in the Law Offices of William M. Shreve, hereby certify that I have this day served the within document upon the persons and in the manner indicated below: Service by First Class Mail: Lynn Blauch 312 Okisco Trail Edenton, NC 27932 ~UN-J ~ ~.~ Dawn E. Minori, Secretary (") ~;. .;:g, (':? ~ .-n ~ cP \ 0' .....,... ,;"\\ .~ '-- ~ '-:\ :.1. ~ :1- i'n~ .."rD :g~J _'1~. .....\ -(;:!~;~\, 8 '::-\ -,: ?','. U\ -' ,~ ~ JANET M. KULIKOWSKI, Plaint if f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OF PENNSYLVANIA vs. CHARLES J. KAUFFMAN, Defendant NO. 00-7996 Civil Term CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Charles J. Kauffman, Defendant, moves the court to appoint a Master with respect to the following claims: (X) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente Lite (X) Distribution of Property ( ) Support ( ) Counsel Fees ( ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims for which the appointment of a Master is requested. (2) The Defendant, Charles J. Kauffman, has appeared in the action by his attorney, Mary A. Etter Dissinger, Esquire. (3) The statutory grounds for divorce are fault and irretrievable breakdown. (4) The action is contested with respect to the following claims: divorce and equitable distribution. (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take one (1) day. Date: vIi) ~tIIn 'j A~~ Mary A. Etter Dissinger Attorney for Defendant 28 N. 32nd Street Camp Hill, PA 17011 717-975-2840 cc: J. Paul Helvy, Esquire Charles J. Kauffman ~ (") ...., 0 <=> c-: = .,., - .to ~~ .." =Tl I:i r}} 're!!: I"Tl -~"1"1 ~ <::0 nl-: G') " I -oS -0 -< U1 or r- =r:S? ~ -0 '. :+i ~:('j ::!I: ~-c;:O PC: ~ ;:'5rn -, ?J ;,.'":>- <::> _0 ,< - ORDER APPOINTING MASTER ()/t/~.l. ~O~'" "';(' , (p 1'1 day of lek V'1/ 2003, ,: 1;.1. ~ ~ Esquire. is appointed Master ...,p:th respect to the following claims: divorce and equitable distribution. BY THE COURT: {)J. , ""-n \-';i\;VF];'~~\'IJ:J: 1 I '<or'-;,. ' . '. ',:c"""''' ,,-U\I /.'... ':"'i,j h.J S l-J :6 H~ 9- 933 ~OOl N:i\ilOi'.O:-ilOU:i JHl. :10 30i:J:lO-G311::l JEFFREY 1. BLAUCH, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 03- 3~OS r..l~ I L<- LYNN S. BLAUCH, DEFENDANT In Divorce NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(c) DIVORCE DECREE To: Lynn S. Blauch, Defendant You have been sued in an action for divorce. 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 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 ofthe Prothonotary at the Cumberland County Courthouse, Prothonotary's Office, I Courthouse Square, Carlisle, PA 17013, (717) 240-6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANED, 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 (717) 249-3166 or 1-800-990-9108 JEFFREY L. BlAUCH, PLAINTIFF VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNlY, PENNSYLVANIA No. 03- 3&'O~- ~ ftM- LYNN S. BlAUCH, DEFENDANT In Divorce COMPWNT UNDER SECTION 3301CCl OF THE DIVORCE CODE 1. Plaintiff is Jeffrey L. Blauch, mailing address of P.O. Box 292, New Cumberland, PA 17070. 2. Defendant is Lynn S. Blauch, believed to be residing at 312 Okisco Trail, Edenton, North Carolina 27932. 3. Jeffrey L. Blauch has been a bOna fide resident in the Commonwealth for at least six months immediately prior to the tiling of this Complaint. 4. Plaintiff and Defendant were married on October 18,1996, in Virginia Beach, Virginia. 5. Plaintiff avers that there are no children of the parties under the age of 18. 6. The defendant Is not In the military or naval services of the United States or its allies, or is otherwise within the provisions of the Soldiers and Sailors Civil Relief Act of Congress of 1940 and its amendments. 7. There have been no prior actions of divorce or for annulment between the parties. 8. 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 to participate in counseling. 10. Plaintiff requests the court to enter a decree of divorce. 1 verify that the statements made in this Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~ 4904, relating to unsworn falsification to authorities. Date: 7 /z ~3 Cl~L-. /: ~c1. J~ffrlJfL.. "uCh, Plaintiff ~/, William M. Shreve Attorney for Plaintiff 10 # 82337 (717) 234-6001 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 (") C.J C) ~ C G.:;' -It F < (0 ~ -otT' ~ 92F ,-- , ,. '~ )/ ~:~,;-~ N ,"-L ~ \.1) ...... "'<' .' ~, -:;'- (:::'1 -<::. ~C' 'TJ , , ." '" ~f:-'. 'T~ \.'\ '" -JA ........ r~~ " ~ >c': .:':"~ C ,.~ ~ ~ '.. -:::: ~ -< '';' -< JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNlY, PENNSYLVANIA VS. No. 03-3605 Civil Term LYNN S. BLAUCH, DEFENDANT In Divorce NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301{dlDIVORCE DECREE To: Lynn S. Blauch, Defendant You have been sued in an action for divorce. 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 custocly 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 at the Cumberland County Courthouse, Prothonotary's Office, 1 Courthouse Square, Carlisle, PA 17013, (717) 240-6195. IF YOU DO NOT FILE A CLAIM FOR AUMONY, DIVISION OF PROPERlY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRAN ED, 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 (717) 249-3166 or 1-800-990-9108 JEFFREY L. BLAUCH, PlAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 03-3~ivil LYNN S. BLAUCH, DEFENDANT In Divorce MOTION TO AMEND COMPLAINT TO SECTlOI'( 3301(d) OF THE DIVORCE CODE 1. On July 29, 2003, a Complaint Under Section 3301(C) of the Divorce Code was filed. 2. The parties have lived separate and apart for greater than two years as required by Section 3301(d) of the Divorce Code. (Affidavit of Separation Attached as Exhibit A). Respectfully Submitted, ~~ William M. Shreve Attorney for Plaintiff 10 # 82337 (717) 234-6001 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 I EXHIBIT "Au JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNlY, PENNSYLVANIA VS. No. 03 - 3605, Civil Term LYNN S. BLAUCH, DEFENDANT In Divorce NonCE To Defendant, if you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SEmON 3;101(D) OF TH~ DIVORCE COo.E 1. The parties to this action separated on April 4, 2002, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. , 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 unsworn falsification to authorities. Date: 2)2-1/ Db . -J~~d&P~h Jeffrey L. auch, Plaintiff Respectfully submitted, ~ Wilham M. Shreve Attorney for Plaintiff ID # 82337 (717) 234-6001 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 ~, ,1 (" I tel t '" "..) (,:,) /------- . JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNlY, PENNSYLVANIA v. 3l.>05 No. 03-36\') Civil LYNN S. BLAUCH, DEFENDANT In Divorce AFFIDAVIT OF SERVICE I, William M. Shreve, hereby certify that I served a true and correct copy of the Amended Complaint Under Section 3301 of the Divorce Code, upon the Defendant, receipt of which is acknowledged on the attached Acceptance of Service. Respectfully submitted, Date: ~r/ ~~ ./ ") "'.....:.~~~:~:~;;;:.... t:.-/Y7~"'--- - William M. Shreve Attorney for Plaintiff Supreme Court No. 82337 (717) 234-6001 P.O. Box 5292 3618 North 6th Street Harrisburg, PA 17110 ~~ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so hat we can return the card to you. . Art h this card to the back of the mailpiece, or the front if space permits. Addressed to: ~'~f'\'" ~\CL~ :)\8 \i-'-I\~ ~ ''-I(\<a-. ,N.~ C Jq~. ~ lolt,\~~ 2. Article Number (Transfer from SelVice label) PS Form 3811. February 2004 D. Is delivery address different from Item 1? If YES, enter delivery address below: 3. Service Type o Certified Mail o Registered o Insured Mail o Agent o Addressee C. Date of Delivery DYes DNa i \ o Express Mail o Return Receipt for Merchandise DC,O.D. 4. Restricted Delivery? (Extra Fee) 7004 1160 0005 2378 8105 Domestic Return Receipt Dves ?,\t$ l02595-02-M.1540 cf (;. .. . .- JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 03 - 3605, Civil Term LYNN S. BLAUCH, DEFENDANT In Divorce MOTION TO VACATE MASTER Jeffrey L. Blauch, Plaintiff, respectfully moves Your Honorable Court to vacate the master with respect to the pending divorce, thereof, states the following: 1. The parties to this action separated on April 3, 2002 and have continued to reside separate and apart for a period of at lease two years. 2. The defendant has received notice of the amended divorce complaint. 3. A Motion to Amend Complaint to 3301 (d) was filed on March 2, 2006. 4. A divorce decree is now appropriate pursuant to 23 Pa.C.S.A. of 3301(d). 5. Plaintiff hereby requests to withdraw his request to have this matter heard before a master. WHEREFORE, For the foregoing reasons, plaintiff respectfully requests that the Master be vacated. ~ William M. Shreve Attorney for Plaintiff 10 # 82337 (717) 234-6001 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 . '" # # JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 03 - 3605, Ovil Term LYNN S~ BLAUCH, DEFENDANT In Divorce CERTIFICATE OF SERVICE AND NOW, this ? ~ of May, 2006, 1, William M. Shreve, hereby certify that I have or will serve the within Motion to Vacate Master upon the persons and in the manner indicated below: Service by First-Class Mail: Lynn Blauch P.O. Box 6061 Chesapeake, VA 23323-6061 ~~ William M. Shreve () ~.' < . " , r--.,) = = c""\ o 11 .--i I,., rnr~ :2r..r:; .~:~ '""( :jQ 1~;~ ,-) ........ ~:> :n -< C-. ~ """"'"-.... , CO ~ 3: o .. '-.0 "' ~ ! .....-/ RECEIVED JUN 08 2006 f' JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 03 - 3605, Civil Term LYNN S. BLAUCH, DEFENDANT In Divorce ORDERVA~AI!ER And Now, this \-1 of . _ ~\:M. iL , 2006, the appointment of a master in this matter is hereby vacated. , Judge Distribution: William M. Shreve, 3618 North Sixth Street, Harrisburg, PA 17110 Lynn Blauch, Defendant, P.O. Box 6061, Chesapeake, VA 23323-6061 Office of Divorce Master, 9 North Hanover Street, Ca~lis~.! PA 17013 pJ~r' , ~~ &~/j-()(. Q- I S :2 ~,!d S I unr 900Z ^t1VJ!Ji\O:~;.LlJUd 3Hl ;:jO 3J!:!:iO-031Ij .. ". JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 03-3605 Civil LYNN S. BLAUCH, 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. The Amended Complaint Under Section 3301(d) of the Divorce Code was filed on March 2, 2006. 2. The Defendant was served with the Amended Divorce Complaint on April 26, 2006. Affidavit of Service and Certified Mail receipt were filed on April 28, 2006. 3. The parties to this action separated on April 3, 2002 and have continued to live separate and apart for a period of at least two years. Respectfully submitted, Date:,~~~ ~".-"'~..__"'. ",..__..m~~~:~,> c--"""~~ William M. Shreve Attorney for Defendant Supreme Court No. 82337 (717) 234-6001 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 C': '. ~} :_:::1 c-.-, [\) ~J; [" . JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 03-3605 Civil- In Divorce LYNN S. BLAUCH, DEFENDANT In Divorce NOTICE OF INTENTIQN TO REQUEST ENTRY OF DIVORCE DE~REE TO: Lynn Blauch, Defendant Jeffrey Blauch, Plaintiff, intends to file with the court the attached Praecipe to Transmit Record 20 days following your receipt of this notice which will be on or after August 20, 2006, requesting that a final decree in divorce be entered. On April 26, 2006, you were served with an Amended Complaint pursuant to Section 3301(d) of the divorce code. Unless you have already filed with the Court a written claim for economic relief, you must do so by the date in the paragraph above, or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or 1-800-990-9108 Respectfully submitted, Date: July 13. 2006 ~?~ William M. Shreve, Esquire Attorney I.D. No: 82337 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 (717) 234-6001 . . . JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 03 - 3605, Civil Term LYNN S. BLAUCH, DEFENDANT In Divorce CERTIFICATE OF SERVICE AND NOW, this day of July, 2006, I, William M. Shreve, hereby certify that I have or will serve the within Notice of Intent to Request entry of Divorce Decree upon the persons and in the manner indicated below: Service by Certified Mail # 7004 1160 0005 2378 7764. Return Receiot Reauested: Lynn Blauch 4836 Morris Neck Road Virginia Beach, VA 23457 ~~ William M. Shreve . .'-' -:;:.;7 ::') " ,-0 ~-. (-- i-"-~ '~~1 -.l L) f.' -' .. ; JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUN1Y, PENNSYLVANIA v. No. 03-3605 Civil LYNN S. BLAUCH, 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. The Amended Complaint Under Section 3301(d) of the Divorce Code was filed on March 2, 2006. 2. The Defendant was served with the Amended Divorce Complaint on April 26, 2006, at 518 Ryland Road, Tyner N.C. 27980-9670183, by certified mail. 3. Affidavit of Service and Certified Mail receipt were filed on April 28, 2006. 4. A Notice of Intent to Request a Decree of Divorce was filed on or about July 17, 2006. 5. The first attempt to serve the Defendant with the Notice of Intent to Request a Decree of Divorce occurred on July 14, 2006, at 4836 Morris Neck Road, Virginia Beach, VA 23457, by certified mail. The United States Post office made two attempts and returned the mail. (Certificate of Service and Returned envelope Attached as Exhibit A). 6. The Defendant, Lynn Blauch, contacted Attorney Shreve's Office by phone and left a message that her new address was P.O. Box 6061, Chesapeake, VA 23323-6061. .. 7. The second attempt to serve the Defendant with the Notice of Intent to Request a Decree of Divorce occurred on August 2, 2006, at P.O. Box 6061, Chesapeake, VA 23323-6061. The United States Post Office made three attempts and returned the mail. (Letter and Returned envelope Attached as Exhibit B). 8. On September 14, 2006, the Notice of Intention to Request Entry of Divorce Decree was sent first class mail with an acceptance of service for Lynn S. Blauch to sign and return. (Letter Attached as Exhibit C). 9. Ms. Lynn Blauch, Defendant, has made no further attempt to contact the Plaintiff with notification of a new address, nor has she advised the Court. 10. The parties to this action separated on April 3, 2002 and have continued to live separate and apart for a period of at least two years. Date://"fG4G' / / Respectfully submitted, ~ Attorney for Defendant Supreme Court No. 82337 (717) 234-6001 3618 North Sixth Street P.O. Box 5292 Harrisburg, PA 17110 EXHIBIT "A" : . . JEFFREY L. BLAUCH, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V5. No. 03 - 3605, Civil Term LYNN S. BLAUCH, DEFENDANT In Divorce CERTIFICATE OF SERVICE AND NOW, this day of July, 2006, I, William M. Shreve, hereby certify that I have or will serve the within Notice of Intent to Request entry of Divorce Decree upon the persons and in the manner indicated below: Service by C~rtifieo Mail # 7004 11600005 2378 7764, Return Rec~ipt . Requested: Lynn Blauch 4836 Morris Neck Road Virginia Beach, VA 23457 ~ William M. Shreve :....".;........~.......,:..."'~tW..... .--""'" .r~ s .~ .~~e (:) - ':::l ~-o1;; ~~.~~ ~ ,,- '.., 'v\ \".' . I)"\ "~j.: \ I. \ 1 \, ,. ..~::~ ,,:1 o q ~.. 9:' t'~, ~ ~ \ ~. \ i':' ('" "~ ..,..,.. ~~. ';.. " , \ "' ~., (. ------- ..,.... \ .:.~. , '. ' ~ ~ 'C. :'l~'" ;. ....... . t [~,. . . EXHIBIT "B" . . ; William M. Shreve Attorney at Law Phone: (717) 234-6001 Fax: (717)234-6050 e-mail: wmshreve@justice.com 3618 North 6th Street P.O. Box 5292 Harrisburg, PA 17110 August 2,2006 Service by Certified Mail # 7004 1160000523787788. Return Receipt Requested: Lynn Blauch P.O. Box 6061 Chesapeake, VA 23323-6061 Re: Blauch v. !Jlauch, No. 03-3605 Civil- In Divorce Dear Ms. Blauch, Enclosed please find a copy of the Notice of Intention to Request Entry of Divorce Decree that was filed with the Court on July 17, 2006. Should you have any questions or concerns, please do not hesitate to contact me. Sincerely, William M. Shreve WMSjwms Enclosure Cc: Jeffrey Blauch --------- " ..,.,\\ .~ /)j;~'\ \ ;t' +~.,. / ~'" ~<> .' -1 V'~ ~ ~\l ......~ V'.... ' <... ~~ \1- -:., . 0 ~ ~ ~ ,V'. 1)<Q(';-t~i- ..~ V'. ~~~ ~ V' \...~ "e ')I'9~O \, . ..~~\.1<..... ~''''\I~..~ ~ .~...~.~ ....., ."'Y', ~: .....,-:: .0 ''0 ~'o .., \).. .. ..... ...~ ,,~ -;: . \ ~/. o~, .............. .." ......... .."" \'I) (~l ul ,,1 (10) ..\-. ....~J '.., C} U' .... , .... (1' -4 .... .... .... Uti i.:: .... ~. '" ".... \01 o~ O~ Q 'l. Q ~ i i I ..... 'fi! :- '~ :-- ..... . .. ;:; . .. :- :..,... ~ ~ :: ::: :. :0..- r .. ~. :.- - .. .. .. .. ;:: : ::; -:- ,~ G ~, \ .1>:,,<, ~~ ~~ g ~ <&'2: ~ ~ ~~ ~'cn ~G' l""'2' ... V) ~ ~ ;:l~ <: ~ '0.. '- \ ~ ~.'''\ 'I"': "'~, \\ g ~. , ,~ l',1 ~ " \ :' \ ,\ ',\ \\ \ '; . c \. .., ~\\' . ;.i,n. .1 ','e; ....I\' \ c:>~ i~~ ~" ~ . \ g..b ;~:a. '..". ~~ c:> '"O.,~, ~ en F ,lC,~\t:rn':'2 ~ ...".,.,,'."\'j ',.- ,~ 1;,"1"" S' ',i ' ,-'-~ 1."'~ ...' - . . EXHIBIT "e" . . . ; William M. Shreve Attorney at Law Phone: (717) 234-6001 Fax: (717) 234-6050 e-mail: wmshreve@justice.com 3618 North 6th Street P.O. Box 5292 Harrisburg, PA 17110 September 14, 2006 Lynn Blauch P.O. Box 6061 Chesapeake, VA 23323-6061 Re: BlaJlch ~ fJl(luch, No. 03-3605 Civil- In Divorce Dear Ms. Blauch, Enclosed please find a copy of the Notice of Intention to Request Entry of Divorce Decree that was filed with the Court on July 17, 2006. In addition, enclosed please find an acceptance of service, which I need you to please sign, date, and provide your Social Security Number. Kindly return this document to me in the self-addressed, stamped envelope provided herein. Should you have any questions or concerns, please do not hesitate to contact me. Sincerely, Q--~~ William M. Shreve WMS/amm Enclosures Cc: Jeffrey Blauch (letter only) JEFFREY L. BLAUCH, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 03 - 3605, Civil Term LYNN S. BLAUCH, DEFENDANT In Divorce CERTIFICATE OF SERVICE AND NOW, this / ~y of November, 2006, !, William M. Shreve, hereby certify that I have or will serve the within Praecipe to Transmit Record upon the persons and in the manner indicated below: Service by First Class Mail: Lynn Blauch P.O. Box 6061 Chesapeake, VA 23323-6061 ~ G C' :--.:> C":'") l...,=-.....I (,:1"' ""~'-;:4 N \.D ..r:- w 'Ou :.<: if.:+: OE if. if. if. if. OE ff. if. OEif. OE if. if. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. JEFFREY L. BLAUCH, PLAINTIFF No. ())3 3605 CIVIL VERSUS LYNN S. BLAUCH, DEFENDANT DECREE IN DIVORCE '22...... JJ.b-t-bv AND NOW, , ~ , IT IS ORDERED AND JEFFREY L. BLAUCH DECREED THAT , PLAI NTI FF, AND LYNN S. BLAUCH , 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; JJ 61J1. 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