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HomeMy WebLinkAbout07-2960DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 07 029!00 HARRY G. RAUDABAUGH, Defendant IN DIVORCE NOTICE TO DEFEND 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 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 Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & SAIDIS, FLOWER & LINDSAY nrrow?s..?ruw 26 West High Street Carlisle, PA Carol J. Linds, Es Attorney Id. 693 26 West Hig ei Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff DONNA J. RAUDABAUGH, Plaintiff V. HARRY G. RAUDABAUGH, Defendant IN DIVORCE COMPLAINT IN DIVORCE COUNTI UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Donna J. Raudabaugh, an adult individual, residing at 25 Horseshoe Road, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Harry G. Raudabaugh, an adult individual, residing at 445 Run Road, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 24, 1999 in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the SAIDIS, F )WR & LINDSAY Arrowffivs-M uw 26 West High Street Carlisle, PA parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. COUNT II UNDER SECTION 3301(a)(6) OF THE DIVORCE CODE : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. pV-. 2 9'6o Cz 2. / 8. The averments in paragraphs 1 through 7 are incorporated herein. 9. Defendant has offered such indignities to Plaintiff, an innocent and injured spouse, as to render her condition intolerable and her life burdensome. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA Dated: SAIDIS, FL WER & Carol J. Lindsay Es Attorney Id. 446 93 26 West High tr Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. Donna J. audabaugh Date: SAMIS, FLOWER & LINDSAY ACIOW''SS.AT IAw 26 West High Street Carlisle, PA f", - ? ? [? _ .Il ...», ? '? Q,? (N X31 C.., ? C . , _Q ai I ? _. ? _? .. ? b -- _;r DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2960 HARRY G. RAUDABAUGH, Defendant IN DIVORCE AFFIDAVIT I, Robert W. Lindsay, Constable, an adult individual not a party to the above-referenced action, being duly sworn according to law, hereby deposes and says that on June, 2007, at f /PM, I served the Complaint in Divorce, by hand delivering the document to the Defendant, Harry G. Raudabaugh, at 445 Run Road, Carlisle, Pennsylvania. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn. falsification to Robert W. L'Mdsay, onst P.O. Box 224 ' Shippensburg, PA 17257 SAWIS ADANTR ,& LINDSAY 26 West High Street Carlisle, PA Dated: G/X cr7 Sw n to and subs ed before me this ?t- day of /-aAAJ 11 20Q NOTARIAL SEAL VIERL CARLISLE CUMBERLAND COTARY tO" PA" W COMMISSION EXPIRES JUNE 8, 2010 7T- G rM+' j ? av i N DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO.07-2960 . , ` HARRY G. RAUDABAUGH, Defendant IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE IS HEREBY GIVEN that Donna J. Raudabaugh, the Plaintiff in the above matter, having filed a Complaint in Divorce on May 18, 2007, hereby intends to resume and hereafter use the previous name of DONNA J. LANDIS, and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980. Donna J. audabaugh TO BE KNOWN AS: SAMIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Donna J. andis ss. ON this, the ? e day of MID , 2007, before me, a Notary 14? Public, personally appeared Donna J. Raudabaugh also known as Donna J. Landis, known to me or satisfactory proven to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. V 4otary Public "At4L4Wft muwv "' BARBARA E. STEBG, Notestr P*ft Carlisle Born, C=berlmd Cvnt My Corm iWon ExPfm lase 71 1 t = O 1 C7 0 a ?? ? c Co -? DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2960 HARRY G. RAUDABAUGH, Defendant IN DIVORCE NOTICE TO DEFEND 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 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 Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER &MNDSAY SAIDIS, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 West High Street Carlisle, PA Carol J. Linda E%quire Attorney IL. 4 . 'tJ3 26 West Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2960 HARRY G. RAUDABAUGH, Defendant IN DIVORCE AMENDED COMPLAINT IN DIVORCE COUNTI UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Donna J. Landis, formerly Donna J. Raudabaugh, an adult individual, residing at 25 Horseshoe Road, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Harry G. Raudabaugh, an adult individual, residing at 445 Run Road, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 24, 1999 in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has SAMIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. COUNT II UNDER SECTION 3301(a)(6) OF THE DIVORCE CODE 8. The averments in paragraphs 1 through 7 are incorporated herein. 9. Defendant has offered such indignities to Plaintiff, an innocent and injured spouse, as to render her condition intolerable and her life burdensome. COUNT III - EQUITABLE DISTRIBUTION 10. The averments of paragraphs 1 through 9 are incorporated herein by reference. 11. In the course of the parties' marriage, they have acquired certain property, both personal and real. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code and to equitably divide the parties' property. Respectfully submitted, SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA Dated: 1 SAIDIS, FLOWER & LINDSAY /%_ 5:?- 19n Carol J. Lindsay Attorney Id. 44 93 26 West High Fee Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. t r Donna J. andis, formerly known as Donna J. Raudabaugh Date: 11-19-03 SAMIS, FLOWER & LINDSAY nnowvevsnruw 26 West High Street Carlisle, PA f^ t?lj Zl ? ? S r' "? d ?? DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2960 HARRY G. RAUDABAUGH, Defendant IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Petitioner, moves the court to appoint a master with respect to the following claims: (X) Divorce (X) Distribution of Property (Equitable Distribution) ( ) Annulment { ) Support ( ) Alimony ( ) Counsel Fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery is not complete as to the claim(s) for which the appointment of a master is requested. (2) The Defendant, appeared in the action and is represented by counsel, (3) The statutory grounds for divorce are §3301(c) and/or (d) (4) Delete the inapplicable paragraph(s). (a) The action is contested. (b) An agreement has been reached with respect to the following claims: NONE. (c) The action is contested with respect to the following claims: ALL. (5) The action does not complex issues of law or fact. (6) The hearing is expected to take: one day (7) Additional information, if any, relevant to the motion: Defendant needs the following information from Plaintiff to proceed: NIA. SAIDIS, FLOWER-4 L,NQ61SAY SAIDIS, FLOWER & LINDSAY AT[ORNE15•A1%1AW 26 West High Street Carlisle, PA _?l g Date: Carol J. Lin s , 26 West High.,Str i Carlisle, PA 13 717-243-6222 ra c-a ') c: ? ? -?- --{ --'y _.?.. -?.,, , ? ? ? r ??-? ?, ? "? -. - _. ? , ;, r.::.? ? :+7? rx7 A i NOV L 4 ZUU8(n DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2960 HARRY G. RAUDABAUGH, Defendant IN DIVORCE ORDER APPOINTING MASTER li AND NOW, this Ca day of 2008, e y?? & Esquire, is appointed master with respect to the following claims: Divorce and equitable distribution. , BY T zwloi J. SAIDIS, FLOWER & LINDSAY AnORNE-F,AT uw 26 West High Street Carlisle, PA -?.1 t: ?? '- ? < - ? _? w ?: ?; ' i.['? .? ?i- CU ? ?::? ?? mow:. Y.. ?' ? C7 c ?? _? ? ?? ??}? DONNA J. RAUDABAUGH, Plaintiff V. HARRY G. RAUDABAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2960 IN DIVORCE PETITION FOR DISCOVERY NOW COMES Donna J. Landis, formerly Donna J. Raudabaugh, by and through her counsel, Saidis, Flower & Lindsay, and petitions this Honorable Court as follows: 1. Petitioner is Donna J. Landis who is represented by Carol J. Lindsay, Esquire. 2. Respondent is Harry G. Raudabaugh who resides at 445 Run Road, Carlisle, Pennsylvania. 445 Run Road is the marital home. Respondent is not represented by counsel. 3. The parties hereto were married on December 24, 1999. Petitioner has filed a Complaint for Divorce with a Count in equitable distribution and has filed for the appointment of the Master. 4. In order to prepare the case for trial, it is necessary to have the marital home appraised which Petitioner is willing to do. On November 13, 2008, through counsel, she requested that Respondent provide a time to her appraiser, Steven Barrett, so that he could gain access to the house to prepare the appraisal. A copy of the letter of November 13, 2008 is attached hereto as Exhibit "A". 5. Upon information and belief, Respondent has not contacted the appraiser to SAWIS, FLOWER & LIlVDSAY A FURNBS•Aiuw 26 West High Street Carlisle, PA arrange for entry into the marital home. 6. Petitioner no longer has access to the marital home in order to arrange for the appraisal herself. 7. It is assumed that Respondent disagrees with the relief requested in this Petition. 8. No judge has been assigned to this case. WHEREFORE, Petitioner prays this Honorable Court to issue a Rule upon the Respondent to show cause why he should not be required to permit the appraisal of the marital home and to cooperate with Steven Barrett to provide entrance to the marital home. SAIDIS, FLOWER & LINDSAY Carol J.-Uridsay,,Es Attorney Id. 4493 26 West High $ Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, LINDSAY ATIOMAM-AMAW 26 West High Street Carlisle, PA LAW OFFICES JOHN E. SLIKE ROBERT C. SAIDIS JAMES D. FLOWER, JR CAROL J. LINDSAY JOHN B. LAMPI DANIEL L. SULLIVAN MICHAEL L. SOLOMON GEORGE F. DOUGLAS, III DEAN E. REYNOSA THOMAS E. FLOWER MARYLOU MATAS SAIDIS, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 EMAIL: attorney@sfl-law.com www.sfl-law.com November 13, 2008 Harry G. Raudabaugh 445 Run Road Carlisle, PA 17013 Re: Divorce Action Dear Mr. Raudabaugh: CAMP HILL OFFICE: 2109 MARKET STREET CAMP HILL, PA 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 REPLY TO CARLISLE As you may recollect, I represent Donna Landis. The time has come to proceed to divide your property in divorce. To that end, I have filed an Amended Complaint, a certified copy of which I enclose with this letter. I have also filed a Motion for the Appointment of the Divorce Master who can hear the case and divide the property and see to it that you and Donna are divorced. In order to prepare for a divorce trial, I need access to the house at 445 Run Road by an appraiser. I will ask Steve Barrett to appraise the real estate. Donna will advance the cost of the appraisal. Mr. Barrett's telephone number is 243-6646. 1 need for you to call Mr. Barrett within the next week to arrange a time when he can come out to the house for the appraisal. If he does not hear from you within the next week, I will file a Motion with the Court to require you to permit Mr. Barrett to appraise the property. I will ask for attorney's fees as well. If you have retained counsel in this regard, would you please ask him or her to get in contact with me? Once we have all of the information required, it may be possible to settle your case short of trial. By copy of this letter, I am alerting Mr. Barrett to expect your call and I will follow up with him in a week to see if he has received it. Thank you for your assistance. Very truly yours, CJL/bes cc: Donna Landis Steven Barrett SAIDIS, FLOWER & LINDSAY Carol J. Lindsay, Esquire 1 VERIFICATION I, Carol J. Lindsay, attorney for Donna J. Landis, formerly Donna J. Raudabaugh, verify that the statements made in the foregoing document are true and correct and certify that I am authorized to do so. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Carol J. Plaintiff SAIDIS, LINDSAY ATIORNEIS•AT•NW 26 West High Street Carlisle, PA CERTIFICATE OF SERVICE On this 3 day of December, 2008, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individuals, via first class mail, postage prepaid, addressed as follows: Harry G.Raudabaugh 445 Run Road Carlisle, PA 17013 SAIDIS, FLOWER & LINDSAY Carol J. Lindsay, s ire Supreme Cou D No. 44693 26 West High treet Carlisle, PA 170 3 717-243-6222 SAIDIS, FLOWER & LINDSAY ATr0FMYS.AT- 26 West High Street Carlisle, PA ?._s €-_ •r > - ri . t .. 3 i.? ??? DEC 0 4 20W 6 DONNA J. RAUDABAUGH, Plaintiff V. HARRY G. RAUDABAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMB RLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2960 IN DIVORCE ORDER ih AND NOW, this 19 day of Z #-' the within Petition, a Rule is issued upon the R requested should not be provided. Rule returnable at a hearing set for the Courtroom No. -5 at the Courthouse in Carlisle, SAMIS, LINDSAY nrrot?s•.?ruw 26 West High Street Carlisle, PA i 1) ?? V4 (,'r , 2008, upon consideration of :)ondent to show cause why the relief day of , 20# in fivania. alt /v' 3 D BY THE COURT, J. AW r3, ILO `X30/L 1 IJ- S :I ? ifJ L ! 330 pool DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 07-2960 HARRY G. RAUDABAUGH, Defendant IN DIVORCE ANSWER TO PETITION FOR DISCOVERY NOW COMES the Defendant, HARRY G. RAUDABAUGH, by and through his attorney, Charles E. Petrie, and respectfully answers Petitioner's Petition for Discovery as follows: 1. Admitted. 2. Admitted in part and denied in part. It is admitted that Respondent is Harry G. Raudabaugh, who resides at 445 Run Road, Carlisle, Pennsylvania, and that 445 Run Road is the marital home. It is denied that Respondent is not represented by counsel. Respondent's attorney is Charles E. Petrie. 3. Admitted. 4. Admitted. 5. Denied. Respondent has contacted Steve Barrett. Mr. Barrett is scheduled to visit the real estate for the purpose of an appraisal on January 8, 2009, at 10:00 a.m. 6. Admitted. 7. Denied. Respondent agrees with the relief requested in Petitioner's Petition. 8. Denied. The Honorable M. L. Ebert, Jr., has been assigned to this case. WHEREFORE, Respondent respectfully requests that Your Honorable Court enter an Order directing that Mr. Steve Barrett shall visit the premises at 445 Run Road, Carlisle, Pennsylvania, on January 8, 2009, for purposes of an appraisal of the real estate. Respectfully submitted, CHARLES E. PETRIE 3528 BRISBAN STREET HARRISBURG, PA 17111 (717) 561-1939 SUP. CT. ID 29029 ATTORNEY FOR RESPONDENT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Upon information and belief, I verify that the statements in the Petition 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. DATE CHARLES E. PETRIE ATTORNEY FOR RESPONDENT DONNA J. RAUDABAUGH, Plaintiff V. HARRY G. RAUDABAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-2960 : IN DIVORCE CERTIFICATE OF SERVICE I certify that I served a copy of the foregoing Answer to Petition for Discovery upon counsel for the Petitioner, Carol J. Lindsay, Esquire, by personal service at the law offices of Saidis, Flower & Lindsay, 26 West High Street, Carlisle, Pennsylvania 17013 on December 31, 2008. CHARLES E. PETRIE 3528 BRISBAN STREET HARRISBURG, PA 1711. 1 (717) 561-1939 SUP. CT. ID 29029 ATTORNEY FOR RESPONDENT DONNA J. RAUDABAUGH, Plaintiff V. HARRY G. RAUDABAUGH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 07-2960 IN DIVORCE PRAECIPE Please enter the appearance of Attorney Charles E. Petrie on behalf of the Defendant, HARRY G. RAUDABAUGH. Respectfully submitted, CHARLES E. PETRIE 3528 BRISBAN STREET HARRISBURG, PA 17111 (717) 561-1939 SUP. CT. ID 29029 ATTORNEY FOR RESPONDENT E r 3, r ,a DONNA J. RAUDABAUGH, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW HARRY G. RAUDABAUGH, NO. 07-2960 Defendant IN DIVORCE PRAECIPE Please enter the appearance of Attorney Charles E. Petrie on b Defendant, HARRY G. behalf of the RAUDABAUGH. Respectfully submitted, CHARLES E. PETRIE 3528 BRISBAN STREET HARRISBURG, PA 17111 (717) 561-1939 SUP. CT. ID 29029 ATTORNEY FOR RESPONDENT r`- 3 a 'E .? 'JAPE 0 2 2M DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW HARRY G. RAUDABAUGH, NO. 07-2960 Defendant IN DIVORCE ORDER AND NOW, this Jt'??? day of 7ahv ar , 2001, , upon consideration of the Petition for Discovery and the Answer thereto, it is hereby Ordered that Mr. Steve Barrett shall visit the premises at 445 Run Road, Carlisle, Pennsylvania, on or about January 8, 2009, at 10:00 a.m. for purposes of a real estate appraisal. The hearing scheduled for January 6, 2009, at 10:30 a.m. is hereby canceled. BY THE COURT: M. L. EBERT, JR., A -- D t 3314 0 a'f i?? DONNA J. RAUDABAUGH, Plaintiff V. HARRY G. RAUDABAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2960 IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on February 23, 2007, and have continued to live separate and apart for a period of at least two years, 2. The marriage is irretrievably broken. 3. 1 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 SAIDIS SULLIVAN LAW 26 West High Street Carlisle, PA that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. g?? / Dated: Z J 2-1J-,Wtt Donna J. udabaugh, now known as Donna J. Landis rnca =rn :Z= ? C--) u -< ' w o _ m cy 1NE PROTf1OjyOj?.[,,, +`V31 i 2011 APR 21 PM 2: 41 CUMBERLAND cvUNry PENNSYLVANIA DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2960 HARRY G. RAUDABAUGH, Defendant IN DIVORCE AFFIDAVIT OF SERVICE Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 I, Marylou Matas, Esquire, being duly sworn according to law, hereby deposes and says that on April 12, 2011 she served a true and correct copy of the 3301(d) Counter-Affidavit and the Notice of Intention to Request Entry of 3301(d) Divorce Decree upon Defendant's counsel, Charles Petrie, Esquire, by mailing those documents to the his address at 3528 Brisban Street, Harrisburg, PA 17111 by Certified U.S. Mail, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient's agent, Kelly Roberts. Dated: J-' I ? I Z,U I Respectfully submitted, SAIDIS, SULLIVAN & ROGERS L Marylo ` tas, Esquire ID No. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2960 HARRY G. RAUDABAUGH, Defendant IN DIVORCE • Ca'nPlete Items 1, 2, and S. Also complete e Is desired. • Prkit your name and address on the verse so that we can retum the card to you. • Attach this card to the back of the mailplece, M nn H.e i.....a is .- Charles Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 --- ,? bent 0 Addma eceiv by '??? Name) C. Date of Delivery L Is delivery address dfferent from Rem 1? 0 Y-- es If YES, enter delivery address below: §1 No ..w ,YW B Certified Mail 0 Express mail 0 Registered 0 Retum Receipt for Merchandise n I..-........-,. - - - 2. Article Number res t7?arrsfi?r horn servke fa6e/) 700 8 130 0 0000 7 571 2827 Ili Form 3811, February 2004 Domestic Return Receipt 102585.024A-1510 SPS - -rack & Confirm Page I of 1 Tracy Confirm Search Results Label/Receipt Number: 7008 1300 0000 7571 2827 Service(s): Certified Mail" Status: Delivered Your item was delivered at 12:41 pm on April 12, 2011 in HARRISBURG, PA 17111. Track & Confirm Enter Label/Receipt Number. Ga Detailed Results: • Delivered, April 12, 2011, 12:41 pm, HARRISBURG, PA 17111 • Notice Left, April 05, 2011, 2:55 pm, HARRISBURG, PA 17111 • Processed through Sort Facility, April 05, 2011, 3:36 am, HARRISBURG, PA 17107 Notification Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. Go. Site Mao Customer Service Forms Gov't Services Careers CopyrightQ 2010 LISPS. All Rights Reserved. No FEAR Act EEC Data FOIAr Privacy Policy Terms of Use Business Customer Gateway http://trkenfrml.smi.usps.com/PTSIntemetWeb/InterLabellnquiry.do 4/14/2011 FILED-OFFIC.c ^ aF THE PROTIJOHCITr,,R 2111 APR 21 PM 2: 43 CUMBERLAND A A? i DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 07-2960 HARRY G. RAUDABAUGH, Defendant IN DIVORCE AFFIDAVIT OF SERVICE Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 I, Marylou Matas, Esquire, being duly sworn according to law, hereby deposes and says that on April 12, 2011 she served a true and correct copy of the 3301(d) Counter-Affidavit and the Notice of Intention to Request Entry of 3301(d) Divorce Decree upon Defendant's counsel, Charles Petrie, Esquire, by mailing those documents to the his address at 3528 Brisban Street, Harrisburg, PA 17111 by Certified U.S. Mail, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient's agent, Kelly Roberts. Dated: 419,411 / Respectfully submitted, SAIDIS, SULLIVAN & ROGERS Mares atas, Esquire ID No. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff DONNA J. RAUDABAUGH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2960 HARRY G. RAUDABAUGH, Defendant IN DIVORCE ¦ Complete items 1, 2, and 3. Also complete A. Sig re Rem 4 If Restricted' Delivery Is desired. ¦ P X A A rint your name and address on the reverse so that we can return the cans to you. E3 ddre ? Addressee ¦ Attach this card to the back of the maiipiece, eceiv by (Pdnted Name) C. Date of Delivery or on the front If space permits. G f j 1. Article Addressed to: D. Is delivery address different from Item 1? ? Yes If YES, enter delivery address below: P No Charles Petrie, Esquire 3528 Brisban Street Harrisburg, PA 17111 3. Service Type IX Certified Mail 0 Express Mail ? Registered 13 Return Receipt for Merchandise ? Insured'Mail 1 C.O.D. 4. Restricted Delivery? (Exha Fee) ? Yes 2. Article Number - ManSWfrom sevba,'at 7008 1300.0000 75-71 2827 PS `Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 UBPS - Track & Contirm ra`e 1 01 1 UNIT STATES Home I Help ? SE57MEt, Sign In Track & Confine FAQs Track & Confirm. Search Results Label/Receipt Number: 7008 1300 0000 7571 2827 Service(s): Certified Mail" Status: Delivered Your item was delivered at 12:41 pm on April 12, 2011 in HARRISBURG, PA 17111. Track & Confirm Enter Label/Receipt Number. GC > Detailed Results: Delivered, April 12,2011,12:41 pm, HARRISBURG, PA 17111 • Notice Left, April 05,2011,2:55 pm, HARRISBURG, PA 17111 Processed through Sort Facility, April 05, 2011, 3:36 am, HARRISBURG, PA 17107 Nati catim Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. -' Go > Site Map Customer Service Forms Govt Services Careers Gopyright© 2014 tlSPS. All Rights Reserved. No FEAR Act EEO Data FOIA Privacy Policy Terms of Use Business Customer Gateway http://trkcnfrml .smi.usps.com/PTSIntemetWeb/InterLabellnquiry.do 4/14/2011 DONNA J. RAUDABAUGH, Plaintiff V. HARRY G. RAUDABAUGH, Defendant PRAECIPE To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2960 IN DIVORCE C rxa V -V Cn r- N) N ? O L7 3n _ 7D --n ;zp .-Z ---C? l Please withdraw Plaintiff's economic claims in the above captioned action. Respectfully submitted, SAIDIS SULLIVAN & ROGERS Maryl"t s, Esquire Supreme GQ4drt ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 DONNA J. RAUDABAUGH, Plaintiff VS. HARRY G. RAUDABAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 2960 Civil IN DIVORCE ORDER OF COURT AND NOW, this day of , I/ C/ 2011, the economic claims raised by the Plaintiff, having been withdrawn by praecipe filed with the Prothonotary on July 22, 2011, and there being no other issues pending before the Master, the appointment of the Master is vacated. BY THE COURT, 04- Kevi,qolr- Hess, P.J. cc: ? Marylou Matas Attorney for Plaintiff ? Charles E. Petrie "D Attorney for Defendant G ? pQ? 0 II E`J? f rn ?= rte- r- -'Or 70 G o oe o "C C) S? CC+ + S L? -n a- DONNA J. RAUDABAUGH, Plaintiff V. HARRY G. RAUDABAUGH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA-,, C C= CIVIL ACTION - LAW X0 .rz NO. 07-2960 =M IN DIVORCE .. > Tr C'? "Z j ? tQ C) PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on June 15, 2007, via personal service by constable. 3. Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: December 27, 2010; filed on December 30, 2010; Defendant served by regular U.S. mail, upon his attorney of record, on December 28, 2010. 4. Related claims pending: None. Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle. PA 17073 5. Date and manner of service of the Notice of Intention to file Praecipe, a copy of which is attached: Defendant served via certified, US mail, upon his attorney of record, on April 12, 2011. SAIDIS SULLIVAN & ROGERS Marylou Matas; Esquire Supreme Court ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 IN THE COURT OF COMMON PLEAS OF DONNA J. RAUDABAUGH : CUMBERLAND COUNTY, PENNSYLVANIA V. HARRY G. RAUDABAUGH NO. 2007-2960 DIVORCE DECREE AND NOW, Q1y (yO S ? 1 2011 , it is ordered and decreed that DONNA J. RAUDABAUGH , plaintiff, and HARRY G. RAUDABAUGH , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, *t? ? ?'a Attest: J. Yid 1J. v°11, P othonot ry -??, led * ,t?s Yed 740 Cori Ind,