Loading...
HomeMy WebLinkAbout07-3474MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 3 4 1 4/ CIVIL TERM : IN DIVORCE NOTICE 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, High and Hanover Streets, Carlisle. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 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. 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. MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 3 `/ 9y CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Michael J. Haggerty, who currently resides at 7073 Carlisle Pike, Lot 57, Carlisle, Cumberland County, Pennsylvania, 17015 since 2001. 2. Defendant is Laurie R. Haggerty, who currently resides at 315 Pinedale Road, Cumberland County, Carlisle, Pennsylvania 17013 since 2001. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on October 28, 1998, in Arlington, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. V WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: 3 Zd?? Respectfully submitted, ROMINGER &ASSOCIATES ok-llk- Michael O. Palermo, Jr.,Ts$c 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 93334 Attorney for Plaintiff VERIFICATION 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. § 4904, relating to unsworn falsification to authorities. Date: 6 - 1 3 -o 7 MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - CIVIL TERM : IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on May 16, 2001, 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. § 4904 relating to unsworn falsification to authorities. Date: 6 -/3 _ v -? C7 C N .`- v'!'` - T R W „? Ti P77 r`i r ' ? ? , ? t3 mo ? C ? o. t - , ?a r. Q CD 4 ! MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT made and entered into this /S? day of goo -7 (year), between j + j f-i f (Zen « 14 A-6 6 f, t2'C"ti' (Wife) residing at and /lAkckaeJ Sose?k 14ca C-4 (Husband) residing at 70'73 C?4 rz l??l? P%Ve- 57p Aat%3(c ek ("1o [ J". WHEREAS, Husband and Wife were married to each other on ©C j vb e-f .906, l( qS (year) at / TP- (%A4 61 , vl??f?p l n\C (City) (S?alte) WHEREAS, a permanent breakdown of the marriage has arisen between us and we are now living separate and apart from each other; and [Use if there are children involved.] WHEREAS, children were born into our marriage as follows: Child's Name Child's Birth Date Child's Sex (hereinafter "children") and it is the further purpose of this Agreement to provide for the future custody, control and support of the said children, and This product does not constitute the rendering of legal advice or services. This product is intended for informational use only and is not a substitute for legal advice. State laws vary, so consult an attorney on all legal matters. This product was not prepared by a person licensed to practice law in this state. AQHHAQHH WHEREAS, it is the desire and intentions of the parties to settle by agreement all of their marital affairs with respect to property, financial matters, [spousal support or maintenance (use if applicable)] [and all issues relating to their children, including custody, visitation, and child support (use if applicable)]. NOW, THEREFORE, in consideration of the premises and the mutual promises and undertakings herein contained, and for other good and valuable consideration, the parties agree to the following: 1. SEPARATION: The parties agree to permanently live separate and apart from the other party, free from any control, restraint, or interference, direct or indirect, by the other party, and in all respects to live as if he or she were sole and unmarried. if. DIVISION OF PROPERTY Husband transfers to Wife as her sole and separate property the following: Nee-4? 15 i)m?e-d oa? ree,,d y - 2. Wife transfers to Husband as his sole and separate property the following: N?( ( ? 0 1J ?tv'. ?(? a??c?. This product does not constitute the rendering of legal advice or services. This product is intended for informational use only and is not a substitute for legal advice. State laws vary, so consult an attorney on all legal matters. This product was not prepared by a person licensed to practice law in this state. AQHHAQHH III. DIVISION OF DEBTS: 1. Husband shall pay the following debts and will not at any time hold Wife responsible for them, and shall indemnify Wife from any liability on same: DebVS ?CASY- 6-erg -UtQtAC-c a-tX? -6ker- Carc o?- 2. Wife shall pay the following debts and will not at any time hold Husband responsible for them, and shall indemnify Husband from any (liability on same: 'De ? VS V\ t,,j e- ?e-o-n a/14 ?mc( Cckf-e IV. ALIMONY - [Choose one of the following]: C1. Both parties hereby agree to waive any rights or claims that either may now have or in the future to receive alimony, maintenance, or spousal support from each other. Both parties understand the full import of this provision. 2. Monthly payments - The shall pay to for his/her support and maintenance the sum of $ per month/week. This sum shall be payable on the day of each and every , commencing on , (year). Said sum will continue until [choose any or all of the following]: (a) the date that either party dies; (b) the date that the receiving spouse remarries; or (c) any other specific date that both of you agree on. Both parties intend that the amount and duration of the payments (may or may not) be modified by a court in the future. 3. Lump sum payment - The parties hereby agree that in full payment of any claims or rights to alimony, spousal support, or maintenance the shall pay to the sum of $ , which shall be payable on , (year). This product does not constitute the rendering of legal advice or services. This product is intended for informational use only and is not a substitute for legal advice. State laws vary, so consult an attorney on all legal matters. This productwas not prepared by a person licensed to practice law in this state. AQHHAQHH V. CHILD CUSTODY AND VISITATION - [Choose one of the following]: 1. The parties agree that it is in the best interest of the child(ren) that the have sole physical and legal custody of the child(ren). We further agree that the custodial parent will make the major decisions regarding the care and upbringing of said child(ren). However, the other parent has the right to be notified of any major decisions. The parties also agree to share in an equitable fashion the child(ren)'s birthday, holidays, and all vacations. Furthermore, the parties agree to allow the other parent to have a frequent and liberal visitation with the child(ren). [Optional] - If the parties cannot agree on future visitation, then the will have the right to be with the child(ren) as follows: (Draft a schedule i.e., vacation periods which the child(ren) will spend with the non-custodial parent.) 2. The Husband and Wife shall share joint legal custody for the minor child(ren). Both parents shall retain full parental rights and responsibilities. Both parents shall confer with one another so that major decisions affecting the best interests and welfare of the child(ren) may be determined jointly, where reasonably possible. We further agree that shall have sole physical custody of the child(ren). Each party shall have full access to the child(ren)'s medical, dental, or school records. The parties shall consult with one another with regards to all medical and educational matters including religious education and training. The parties also agree to share in an equitable fashion the child(ren)'s birthday, holidays and all vacations. Furthermore, the parties agree to allow the other parent to have a frequent and liberal visitation with the child(ren). The non-custodial parent will have the right to be with the child(ren) at least, but not limited to, as follows: (Note: make a detailed schedule). VI. CHILD SUPPORT Subject to the power of the court to modify these terms, shall pay to as and for child support, the sum of $ per This product does not constitute the rendering of legal advice or services. This product is intended for informational use only and is not a substitute for legal advice. State laws vary, so consult an attorney on all legal matters. This product was not prepared by a person licensed to practice law in this state. AQHHAQHH month/week. This sum shall be payable on the first day of each and every commencing on , (year). Said sum shall continue until the child(ren) shall have married, died, become self-supporting, or reach the age of eighteen (or, if in Alabama, nineteen). [Furthermore, if the parent obligated to pay said support receives an increase in salary or income in the future, the amount of child support shall increase proportionately.] Said sum shall be reduced by $ (or shall be reduced proportionately) for each child to reach the age of eighteen (or, if in Alabama, nineteen) or otherwise emancipated. The parties agree that the will carry and maintain life insurance naming the child(ren) as irrevocable beneficiary(ies). Said life insurance is in the amount of Furthermore, it is agreed that will carry and maintain adequate health, dental, and hospitalization insurance for the child(ren)'s benefit. The shall each year transmit to the evidence of payment showing that such dues, premiums and assessments have been paid. VII. NECESSARY DOCUMENTS The parties agree to execute and deliver to the other party any documents that may be reasonably required to accomplish the intention of this instrument and shall do all other necessary things to this end. VIII. INCOME TAX: For the year I ? 9 9 the parties hereto shall file separate income tax returns. Each party hereto shall receive the refund or pay additional taxes based on his or her separate income. [Or] The parties agree to file a joint income tax return for the year . In the event that there is a credit of any tax payment the shall pay the (1/2, 1/3) of any tax payments. This product does not constitute the rendering of legal advice or services. This product is intended for informational use only and is not a substitute for legal advice. State laws vary, so consult an attorney on all legal matters. This productwas not prepared by a person licensed to practice law in this state. AQHHAQHH [Use if child(ren) are involved.] The parties agree that the may claim the federal dependency tax exemption for the child(ren). IX. SUBSEQUENT DISSOLUTION OF MARRIAGE: It is agreed that this Agreement may be offered into evidence by either party in any dissolution of marriage proceeding, and if acceptable to the Court, this Agreement shall be incorporated by reference in any Final Judgment that may be rendered. However, notwithstanding incorporation in the Final Judgment, this Agreement shall not be merged in it but shall survive the Final Judgment and be binding on the parties for all times. X. REPRESENTATION: The parties represent to each other: (a) Each had the right to independent counsel. Each party fully understands their legal rights and each is signing this Agreement freely and voluntarily, intending to be bound by it. (b) Each has made a full disclosure to the other of his or her current financial condition. (c) Each understands and agrees that this Agreement is intended to be the full and entire contract of the parties. (d) Each agrees that this Agreement and each provision of it is expressly made binding upon the heirs, assigns, executors, administrators, successors in interest and representatives of each party. XI. CHANGE OF NAME: The parties agree that the Wife may have her na e changed or restored to: L&U-0-e_ A *qO ?jej5co XII. WAIVER OF BREACH: No waiver of any breach by any party of the terms of this Agreement shall be deemed a waiver of any subsequent breach. This product does not constitute the rendering of legal advice or services. This product is intended for informational use only and is not a substitute for legal advice. State laws vary, so consult an attorney on all legal matters. This product was not prepared by a person licensed to practice law in this state. AQHHAQHH XIII. ENFORCEMENT OF AGREEMENT: Both parties agree that the Court granting the divorce, at the request of either party, insert in the Final Judgment a reservation of jurisdiction for the purpose of compelling either party to perform this Agreement, or any part thereof. The prevailing party shall be entitled to attorney's fees in connection with such proceedings. XIV. GOVERNING LAW: This Agreement shall be interpreted and governed by the laws of the State of pe ik a S Y 1 u.51tn kG ife s Signature VIE State of f`,eAAS5(1 V?« ) County of r t, rn bey ) On 5- 1-c;,-7 before me, -30yan"t" lr, C- war , personall appeared v tc Ue-e,<e- and c-kk Z>`! 4 / personally known to me (or prove to me n the basis of satisfactory evidence) to be t Ye person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to ire that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. WITNES v han and official seal. Signatue.. ??-?/ - Affiant Known f?C Produced ID Si nature ar Type of ID :PfN ??rve?s L ; cis COMMONLTH OF PENNSYLVANIA Notarial Seal Joseph L. Grove, Notary Public Silver Spring Twp., Cumberland Courity My Commission Expires June 18, 2009 Member, Pennsylvania Association of Notaries This product does not constitute the rendering of legal advice or services. This product is intended for informational use only and is not a substitute for legal advice. State laws vary, so consult an attorney on all legal matters. This product was not prepared by a person licensed to practice law in this state. AQHHAQHH Signed in the presence of: Signed in the presence of: On 5-1 .0"1 before me, ?. L-C-1covit- , personally appeared ( and au t lnCL cit personally known to me (or proved to me on he basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executedThe instrument. WITNES,Slmv paid and official seal. Signatu Affiant Known Produced ID 7 kgnatu No ary COMMONW Of MN v r L:cxx+s Notarial Seal (Seal) Joseph L. Grove, Notary Public Saver Spring Twp., Cwterland County W Comrnisslon Expires June 18, 2009 Member, Pennsylvania Association of Notaries IF A NONLAWYER HELPED YOU FILL OUT THIS FORM THEY MUST FILL IN THE BLANKS BELOW (fill in all blanks): I (name of nonlawyer) , nonlawyer located at (street) (city) (state) , (phone) helped (name) who is the [v/ one only] petitioner or []respondent, fill out this form. This product does not constitute the rendering of legal advice or services. This product is intended for informational use only and is not a substitute for legal advice. State laws vary, so consult an attorney on all legal matters. This product was not prepared by a person licensed to practice law in this state. AQHHAQHH State of rem\s kvbu- IC--, ) County of , ? ??! ?t..? ?? f` ? ? -';'1 ??? . ? ` 4 j ? - ? ` . . .. •S-? 1 fry ? ?"f MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 3474 CIVIL. TERM : IN DIVORCE CERTIFICATE OF SERVICE I, Linda J. Jumper, Paralegal for Rominger & Associates Law Firm do hereby certify that I served a copy of the Divorce Complaint upon the following by depositing same in the United States mail, postage prepaid, on June 14, 2007, at Carlisle, Pennsylvania. The Complaint was also sent certified mail/return receipt/restricted delivery on June 14, 2007, addressed as follows: Laurie R. Haggerty 315 Pinedale Road Carlisle, PA 17013 Dated: o? G -/ ,ry inda J. Jumper aralegal RoMINGER & ASSOCIATES Attorneys at Law Karl E. Rominger Leslie A. Tomeo* Michael O. Palermo, Jr. *Also admitted in New Jersey June 14, 2007 Laurie R. Haggerty 315 Pinedale Road Carlisle, PA 17013 Dear Ms. Haggerty: Enclosed please find a certified copy of a Divorce Complaint which I have filed on behalf of my client, Michael Haggerty. Attached to the Complaint is an Affidavit Under Section 3301 (d) of the Divorce Code along with a Counter Affidavit for you. If you do not wish to oppose the entry of the divorce, you do not need to file the Counter Affidavit. I have also enclosed an Intention to Request Entry of Divorce Decree. If you do not respond to the Affidavit, my office will move forward to finalize the divorce after July 6, 2007. If you have any questions, you should consult with an attorney of your own choosing. Sincerely, r Michael O. Palermo, Jr., Esquire MOP:Ijj Enclosure 155 South Hanover Street, Carlisle, Pennsylvania 17013 • Tel: (717) 241-6070 • Fax: (717) 241-6878 www.romingerlaw.com ADVOCACY • ADVICE • ANSWERS Laurie R. Haggerty 315 Pinedale Road Carlisle, PA 17013 Certified Mail/Return Receipt/Restricted Delivery IN , r r % ?, 4 71 V141 o3l-411 133 __--_--- 3Nil 4 31100:v O-i; ;:s737 0'a V uri:Z 7H7 Z ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ?GUri 30 Ca/- Its fe 17013 A. Signature 13 Agent X ? Addressee B. Received by (Printed Name) C. Date of Delivery D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ONO 3. Service Type Certified mail ? Express man ? Registered _Mfietum Receipt for Merchandise ? Insured-Mail.. ._O C.O.D. 4. Y. 2. Article Number (Transfer from service label 7006 0100 0007 1050 6597 PS Form 3811, February 2004 Domestic Return Receipt 102595.02-M-1540 RoMINGER & ASSOCIATES Attorneys at Law Karl E. Rominger Leslie A. Tomeo* Michael O. Palermo, Jr. *Also admitted in New Jersey June 14, 2007 Laurie R. Haggerty 315 Pinedale Road Carlisle, PA 17013 Certified Mail/Return Receipt/Restricted Delivery Dear Ms. Haggerty: Enclosed please find a certified copy of a Divorce Complaint which I have filed on behalf of my client, Michael Haggerty. Attached to the Complaint is an Affidavit Under Section 3301 (d) of the Divorce Code along with a Counter Affidavit for you. If you do not wish to oppose the entry of the divorce, you do not need to file the Counter Affidavit. I have also enclosed an Intention to Request Entry of Divorce Decree. If you do not respond to the Affidavit, my office will move forward to finalize the divorce after July 6, 2007. If you have any questions, you should consult with an attorney of your own choosing. Sincerely, Ai2 Michael O. Palermo, Jr., Esquire MOP:Ijj Enclosure cc. Michael Haggerty w/enclosure fix! 155 South Hanover Street, Carlisle, Pennsylvania 17013 • Tel: (717) 241-6070 • Fax: (717) 241-6878 www.romingerlaw.com ADVOCACY • ADVICE • ANSWERS n 73 ? ? ? C MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 3474 CIVIL TERM : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Laurie R. Haggerty, Defendant: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the plaintiffs affidavit. Therefore, on or after July 6, 2007, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 Phone: (717) 249-3166 (800) 990-9108 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. E'3 CD `n "13 C :ss r-n MICHAEL J. HAGGERTY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW LAURIE R. HAGGERTY, : NO. 07 - 3474 CIVIL TERM 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. Grounds for divorce: irretrievable breakdown under § 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: June 14, 2007, certified mail, returned, three attempts. Exhibit "A". First class mail to 315 Pinedale Road, Carlisle, PA 17013, not returned. 3. Related claims pending: None- Martial Settlement Agreement incorporated into but not merged with the Divorce Decree. 4. (1) Date of execution of the Plaintiff's Affidavit required by §3301 (d) of the Divorce Code: June 13, 2007 ; (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: Filed, June 13, 2007, served June 14, 2007. 5. Date and manner of service of the Intention to Request Entry of Divorce Decree, a copy of which is attached: June 14, 2007, certified mail, and first class mail. Exhibit "B". rd Date: 1007 Michael O.Palermo, ., Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 93334 r-? Q ? ? ?? ? E .. t t l f`% ?,,??-?yy ,? ??..??1yy ? '.?>L? ? .. r ? ?, ?? t^'C'? '? ? .. - } t _?' ? ? ? ?; r° MICHAEL J. HAGGERTY, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURIE R. HAGGERTY, DEFENDANT 07-3474 CIVIL TERM ORDER OF COURT AND NOW, this day of August, 2007, the request for the entry of a final decree in divorce IS DENIED at this time.' By the Edgar B. Bayley, J. /Michael 0. Palermo, Esquire For Plaintiff 3urie R. Haggerty, Pro se ?- 15 Pinedale Road Carlisle, PA 17013 J :sal ' The record does not reflect service of the complaint by mail as allowed by Pa. Rule of Civil Procedure 1930.4(c). The record reflects that the certified mail was returned unclaimed which pursuant to subsection (c)(2), requires that service shall be made by another means pursuant to the Rules. c'1 :$ wv 8-- onv toot AWiONGl- LOW 3'Hi. JO MICHAEL J. HAGGERTY, . Plaintiff V. LAURIE R. HAGGERTY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 - 3474 CIVIL TERM IN DIVORCE Petition for Service of Divorce By Publication AND NOW, comes Michael J. Haggerty, by and through privately retained counsel Michael O. Palermo, Jr., Esquire, and requests that this Honorable Court allow him to serve an Intent to Request a Divorce by Publication and in support there of avers as follows: 1. The Complaint in Divorce was filed June 13, 2007. (attached as Exhibit "A') 2. Defendant's last known mailing address was 315 Pinedale Road, Carlisle, Pennsylvania. 3. Petitioner's counsel mailed a certified copy of the Divorce Complaint to Respondent by certified and first class mail on June 14, 2007. Attached as Exhibit B". 4. Undersigned counsel did not receive the first class back but the certified mail was unclaimed. Attached as Exhibit "C". 5. Defendant was last known to reside in the Carlisle area. 6. Defendant has not been heard from recently and Plaintiff has not been able to locate her. Also Plaintiff has been in touch with Defendant's brother and he is unaware of Defendant's whereabouts. 7. There are no property issues in the divorce as a Marital Settlement Agreement was signed on May 1, 20007 and will be incorporated into the Divorce Decree. 8. Plaintiff now asks that this Honorable Court consider that service by publication will be adequate for purpose of allowing the Divorce to move forward. 9. Plaintiff would then ask that this Honorable Court consider that such service be adequate for purpose of finalizing the divorce. 10. Plaintiff requests that he be permitted to publicize the Intent to Request a Divorce by Publication in the Carlisle Evening Sentinel as the official newspaper for Cumberland County. WHEREFORE, Plaintiff requests that this Court allow service by publication as requested above. Respectfully Submitted, ROMINGER & ASSOCIATES Date: 4 MAka Michael O. Palermo, ., Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff MICHAEL J. HAGGERTY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW LAURIE R. HAGGERTY, : NO. 07 - 3474 CIVIL TERM Defendant : IN DIVORCE VERIFICATION Michael O. Palermo, Jr., states that he is attorney for, Plaintiff in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C. S. Pa. C.S.§4904, relating to unsworn falsification to authorities. Dated: - ?J 6 F &kv'.' -CO4- Michael O. Palermo, ., Esquire Attorney for Plaintiff MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 317`1 CIVIL TERM : IN DIVORCE NOTICE 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, High and Hanover Streets, Carlisle. 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. h3 4 n YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DQ-NOT.4 HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE:dFFICS-SET1 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. -' i c. Cumberland County Bar Association 32 South Bedford Street -- '' " .. a Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 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. 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. PLAINTIFF'S EXHIBIT W PC PC MICHAEL J. HAGGERTY, . Plaintiff . v. LAURIE R. HAGGERTY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 - X0'1 CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION XIAd) OF THE DIVORCE CODE 1. Plaintiff is Michael J. Haggerty, who currently resides at 7073 Carlisle Pike, Lot 57, Carlisle, Cumberland County, Pennsylvania, 17015 since 2001. 2. Defendant is Laurie R. Haggerty, who currently resides at 315 Pinedale Road, Cumberland County, Carlisle, Pennsylvania 17013 since 2001. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on October 28, 1998, in Arlington, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: 13 Z U o -` Respectfully submitted, ROMINGER &ASSOCIATES ?L k- O. Palermo, Jr., 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 93334 Attorney for Plaintiff VERIFICATION 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. § 4904, relating to unsworn falsification to authorities. Date: _ 13 - C) MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - CIVIL TERM : IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on May 16, 2001, 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. § 4904 relating to unworn falsification to authorities. Date: ?; -13 `v RoMINGER & ASSOCIATES Attorneys at Law Karl E. Rominger Leslie A. Tomeo* Michael O. Palermo, Jr. *Also admitted in New Jersey June 14, 2007 Laurie R. Haggerty 315 Pinedale Road Carlisle, PA 17013 Dear Ms. Haggerty: Enclosed please find a certified copy of a Divorce Complaint which I have filed on behalf of my client, Michael Haggerty. Attached to the Complaint is an Affidavit Under Section 3301 (d) of the Divorce Code along with a Counter Affidavit for you. If you do not wish to oppose the entry of the divorce, you do not need to file the Counter Affidavit. I have also enclosed an Intention to Request Entry of Divorce Decree. If you do not respond to the Affidavit, my office will move forward to finalize the divorce after July 6, 2007. If you have any questions, you should consult with an attorney of your own choosing. Sincerely, Michael O. Palermo, Jr., Esquire MOP:Ijj Enclosure 155 South Hanover Street, Carlisle, PLAINTIFF'S ? EXHIBIT Q ?enns www.romingerlaw.com 241-6070 • Fax: (717) 241-6878 ADVOCACY • ADVICE • ANSWERS ROMINGER & ASSOCIATES Attorneys at Law Karl E. Rominger Leslie A. Tomeo* Michael O. Palermo, Jr. *Also admitted in New Jersey June 14, 2007 Laurie R. Haggerty 315 Pinedale Road Carlisle, PA 17013 Certified Mail/Return Receipt/Restricted Delivery Dear Ms. Haggerty: Enclosed please find a certified copy of a Divorce Complaint which I have filed on behalf of my client, Michael Haggerty. Attached to the Complaint is an Affidavit Under Section 3301 (d) of the Divorce Code along with a Counter Affidavit for you. If you do not wish to oppose the entry of the divorce, you do not need to file the Counter Affidavit. I have also enclosed an Intention to Request Entry of Divorce Decree. If you do not respond to the Affidavit, my office will move forward to finalize the divorce after July 6, 2007. If you have any questions, you should consult with an attorney of your own choosing. Sincerely, Michael O. Palermo, Jr., Esquire MOP:Ijj Enclosure cc. Michael Haggerty w/enclosure 155 South Hanover Street, Carlisle, Pennsylvania 17013 • Tel: (717) 241-6070 • Fax: (717) 241-6878 www.romingerlaw.com ADVOCACY • ADVICE • ANSWERS 71Vw__ 1031911 U33 ----.--- - 3Nil ?3110Q 1V OZO. s;auOoV NtlfN 7,7;; ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: (? 'lrCarl F Awe?4y. l Jc , //1P CeL?? ecl, A. Signature X 13 Agent ? Addressee B. Received by( Printed Name) C. Date of Delivery D. Is delivery address different from item 1 ? ? Yes If YES, enter delivery address below; J2"O 3. Service Type 1211Certified Mail 0 Express Mail 0 Registered WAetum Receipt for Merchandise 0 Insured.Mail 0 C.O.D. 4.) 2. Article Number (Transfer from service )ebei 7006 0100 0007 1050 6597 P5 Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 ;er & Associates ath Hanover Street Pennsylvania 17013 Laurie R. Haggerty 315 Pinedale Road Carlisle, PA 17013 Certified Mail/Return R eceipt/RE JUN 15. M = :stricted Delivery a PLAINTIFF'S U1 EXHIBIT a J J Q }-J _-D CN ?{-rt MICHAEL J. HAGGERTY, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW LAURIE R. HAGGERTY, : NO. 07 - 3474 CIVIL TERM Defendant : IN DIVORCE Amended Petition for Service of Divorce By Publication AND NOW, comes Michael J. Haggerty, by and through his counsel, Michael O. Palermo, Jr., Esquire and amends his Petition for Service of Divorce by Publication as follows: 1. The Honorable Edgar Bayley previously ruled in this divorce matter by entering an Order on August 8, 2007, denying the request for entry of a final divorce decree. Respectfully Submitted, ROMINGER & ASSOCIATES ' Date:OAA Michael O. Palermo, , Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff C`? ?a C) r I ---t - c 'il `r M.- t . E.: r['l r2 :jj MICHAEL J. HAGGERTY, Plaintiff v. LAURIE R. HAGGERTY, Defendant AND NOW, this Plaintiffs request to effectuate AUG 2 0 2007 A-Xj : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 3474 CIVIL TERM : IN DIVORCE ORDER day of , 2007, upon motion of Plaintiff, by publication is granted. Service shall be considered complete thirty (30) days after publication of Notice of Intent to Request a Divorce in the Carlisle Evening Sentinel. Grant of divorce can then be requested. / Distribution: Michael O.Palermo, Jr., Esquire Plaintiff's Attorney S?q ?sd s , ? ?I . ............ ?a* Iva t uc- - CA-- '?o - av'14z? ?- ? N CO tar ;.?. t/? w Y fit- G, Ca C_7 N MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 2Y7Y CIVIL TERM : IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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 unsworn falsification to authorities. 0I Date: urie R. Haggerty/D fe t NOTICE: If you do not wish to oppose the entry of a divorce decree and you lo not i h to make any claim for economic relief, you need not file this counter-affidavit. ? (? -? ? ? ? e t - _ ..? `?: l"'*? ?. ?rt ?. MICHAEL J. HAGGERTY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW LAURIE R. HAGGERTY, : NO. 07 - 3474 CIVIL TERM Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce, Affidavit, Counter-Affidavit, and Notice of Intention to Request Divorce Decree, on behalf of the Defendant, Laurie Haggerty, in the above- captioned action and I certify that I am authorized to do so. t DATE By: Jane Al ander, quire Attorn for Defendant ?`? ?' C:? ?- ?==% -n -s ? .? .,.-- ? 1 .... _ ..e# '...s '.. _' -_. '1'. _ ?? ;tilt MICHAEL J. HAGGERTY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW LAURIE R. HAGGERTY, : NO. 07 - 3474 CIVIL TERM Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Michael J. Haggerty, Plaintiff, 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 ( ) Costs and Expenses and in support of the Motion states: 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. The defendant has appeared in the action by her attorney, Jane Alexander, Esquire. 3. The statutory ground(s) for divorce are irreconcilable differences. 4. The action is contested with respect to the following claims: Distribution. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1 day. Date: Respectfully submitted, ROMINGER & ASSOCIATES hael O. Palermo, Jr., Esquire M 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff ' a? ? " ? .r+ C1 .Tti,. ? ..e^:, ?? ""et "" 1 ?t,A ,_.7, ',? +^'' ;; f .,, .. C"`'7 .•h MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant APR 182006 r4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 3474 CIVIL TERM : IN DIVORCE ORDER APPOINTING MASTER AND NOW, this 1 ° ? day of , 2008, Esquire, is appointed Master with respect to the following claims: & ., -- ?"? r By the Court: G J. Distribution: A ichael O. Palermo, Jr., Esquire L,"J"ane Alexander, Esquire Car I ts en.', i LL Wa-l/'o 8 ti/q cl? LL ? ` c;X7 ==ti = Li r Pt = - '- - . 0 C%q MICHAEL.I. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 3474 CIVIL TERM : IN DIVORCE PLAINTIFF'S PETITION FOR BIFURCATION TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Plaintiff, Michael J. Haggerty, by and through his attorney, Michael 0. Palermo, Jr., Esquire and avers the following: 1. Plaintiff, Michael J. Haggerty is an adult individual who resides 7073 Carlisle Pike Lot 57, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant Laurie R. Haggerty is an adult individual who is believed to be residing at 315 Pinedale Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. On June 13, 2007, your Petitioner initiated an action for divorce. 4. The parties have not lived together for approximately (8) eight years. 5. Petitioner previously submitted his Praecipe to Transmit Record on or about June 23, 2007. The Court would not allow the Divorce to be finalized as service was not complete. Attorney Jane Alexander signed an Acceptance of Service on or around September 27, 2007 for the Divorce Complaint, Affidavit and Counter-Affidavit on behalf of the Defendant 6. There is no reason why Respondent needs to remain married to Petitioner. 7. Petitioner wishes to remarry. 8. Bifurcation will not prejudice the rights of either party. WHEREFORE, Petitioner respectfully requests that this Honorable Court issue a Rule upon Wife to show cause why a bifurcated Decree in Divorce should not be entered with the following provisions: (a) All economic issues or other marital claims shall be preserved; (b) The Dead Man's Rule and the provisions of the Dead Man's Statute shall be waived in the event of the death of either party hereto prior to final resolution of all economic issues of other marital claims; and (c) Until final resolution of all the economic issues or other marital claims, the parties hereto are hereby enjoined from alienating, assigning, concealing, conveying, dissipating, encumbering, pledgiinng, secreting, transferring or otherwise disposing of any marital property. Date: ?( V Respectfully Submitted, ROMINGER & ASSOCIATES Michael O. Palermo, squire 155 South Hanover Street Carlisle, Pa 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 3474 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Plaintiffs Petition for Bifurcation upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Date:mw,h 39 r, 'evi Jane M. Alexander, Esquire 148 South Baltimore Street P.O. Box 421 Dillsburg, Pa 17019 Respectfully Submitted, ROMINGER & ASSOCIATES Michael O. Palermo, Jr., ire 155 South Hanover Street Carlisle, Pa 17013 (717) 241-6070 Supreme Court ID # 93334 MICHAEL J. HAGGERTY, Plaintiff V. LAURIE R. HAGGERTY, Defendant AN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 3474 CIVIL TERM : IN DIVORCE ATTORNEY'S VERIFICATION Michael O. Palermo, Jr.. Esquire, states that he is the attorney for Plaintiff in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: 31 'u ('Di Michael O. Palermo, Jr., uire -U O TW PROThMTARY 209 WR -I PM 3= 44 CUMBER A.K) C)D(A'TY PDtC A A. MICHAEL J. HAGGERTY, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURIE R. HAGGERTY, DEFENDANT 07-3474 CIVIL TERM ORDER OF COURT -3?4 AND NOW, this day of April, 2009, a Rule is issued against Laurie R. Haggerty to show cause why the within divorce case should not be bifurcated. Rule returnable at a hearing to be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 11:00 a.m., Monday, May 4, 2009. By the Court, Edgar B. Bayley, J. Xichael O. Palermo, Jr., Esquire For Michael J. Haggerty /a'me Alexander, Esquire J Far Laurie R. Haggerty :sat 19 ?IINOI.J; i-A ZZ :l1 RV C- Hd oz 1?W1CX? Cbd -Hi d0 30 WD-a3lU MICHAEL J. HAGGERTY, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURIE R. HAGGERTY, DEFENDANT 07-3474 CIVIL TERM ORDER OF COURT AND NOW, this 4A%-- _day of May, 2009, this matter having been called for a hearing this date, IT IS ORDERED that the petition of Michael J. Haggerty to bifurcate a divorce from the economic claims raised therein, IS GRANTED. Michael O. Palermo, Jr., Esquire Fo Michael J. Haggerty Jane Alexander, Esquire Laurie R. Haggerty sal 0-6 ez rnlaL t i Edgar B. Bayley, J. 3 n ?• y_} C-i MICHAEL J. HAGGERTY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW LAURIE R. HAGGERTY, : NO. 07 - 3474 CIVIL TERM Defendant : IN DIVORCE AMENDED 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. Grounds for divorce: irretrievable breakdown under § 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service signed by Jane Alexander, Esquire on October 1, 2007, filed with Prothonotary, October 1, 2007. 3. Related claims pending: Economic claims. Order entered on May 4, 2009, by the Honorable Edgar B. Bayley granting a Petition to Bifurcate a Divorce. Attached as Exhibit "A". 4. (1) Date of execution of the Plaintiffs Affidavit required by §3301 (d) of the Divorce Code: June 13, 2007 ; (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: Filed, June 13, 2007, served October 1, 2007. 5. Date and manner of service of the Intention to Request Entry of Divorce Decree: Acceptance of Service, Jane Alexander, Esquire, October 1, 2007. Date: I , 2009 Michael O.Palerm ., Esquire 155 South Hanover t Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 93334 MICHAEL J. HAGGERTY, IN T E OURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LAURIE R. HAGGERTY, DEFENDANT 07-3474 CIVIL TERM ORDER OF COURT AND NOW, this day of May, 2009, this matter having been called for a hearing this date, IT IS ORDERED that the petition of Michael J. Haggerty to bifurcate a divorce from the economic claims raised therein, IS GRANTED. Michael O. Palermo, Jr., Esquire For Michael J. Haggerty Edgar B. Bayley, J. i Jane Alexander, Esquire Laurie R. Haggerty :sal jF4 y.J(j'?1`(?1 i? i- 1 a f•y'x/ ??.yry. vi "i?`VY ?wii~ l y??,?i?,A1i??.6Ao?+i`?Y 1r0 ?1g?an :,r?l Ity+at ca 10111d at ?srage , Pa _Y,691_7- C O TFE -P, 2009 MAY 1 2 f i l 3: 33, ^. 3Y d MICHAEL J. HAGGERTY V. LAURIE R. HAGGERTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3474 CIVIL TERM DIVORCE DECREE AND NOW,, it is ordered and decreed that MICHAEL J. HAGGERTY , plaintiff, and LAURIE R. HAGGERTY , 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.") Economic claims. 11 By toe Court, Attest: J. rothonotary a? °oq s -elf MICHAEL J. HAGGERTY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 07 - 3474 CIVIL LAURIE R. HAGGERTY, Defendant IN DIVORCE ORDER OF COURT AND NOW, this day of , 2009, a divorce decree having been entered pre usly on May 19, 2009, and no economic claims having been raised, the appointment of the Master is vacated. Cc: ? /Michael 0. Palermo, Jr. Attorney for Plaintiff ane M. Alexander Attorney for Defendant ;-joy BY T114-COURT, Edgar-B. Bayley, P.J. E=lL?[J--???=? ICS _ _ OF THE P=i; ,, -TAPY 2009 jU i' 12 Al"I g: 28