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HomeMy WebLinkAbout07-4673KELLI S. HARMAN-LEVINSKY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW vs. No. 07- yG.73 c~,c~-~I TERRY L. LEVINSKY, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. if you wish to defend against the claims set forth in the foregoing 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 in 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; Office of the Prothonotary Cumberiand County Courthouse 1 Courthouse Square Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY ,DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 KELLI S. HARMAN-LEVINSKY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW vs. TERRY L. LEVINSKY, Defendant No. 07 -'~~"13 e~;«~~I IN DIVORCE COMPLAINT IN DVORCE AND NOW comes the above-named Plaintiff, KELLY S. HARMAN-LEVINSKY, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is KELLI S. HARMAN-LEVINSKY, an adult individual who currently resides at 5455 Bonny Rigg Court in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is TERRY L. LEVINSKY, an adult individual who currently resides at 2912 S. Queen Street in Dallastown, York County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 14, 2005 in Carroll County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I -IRRETRIEVABLE BREAImOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. uel L. es Attorney for Plaintiff Supreme Court ID # 17225 525 North 12'" Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct, I understand that any false statements in this Complaint are subject to the penalties of 18 Pa, C.S. 4904 (unsworn falsification to authorities), Date; J 4 KELLI S, HARM -LEVINSKY ~ ~ T ~ ~ ~ ~ f~, J~_. ~ ~ ~ ~._ ~ ~ d ~~: r ~ ~~'- ~~.. ~~ s O ~~ ~~ ~~ '~ (~3 ~~ Kelli S. Harman-Levinsky IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND PENNSYLVANIA vs. CIVIL ACTION Terry L. Levinsky NO. 07-4673 Defendant IN DIVORCE 1-CCSPT]!NC'S OF S~RYICE / SiITRY OF lIPP$AR]-1~Cg I, Mary A. Etter Dissinger, hereby enter my appearance on behalf of Defendant, Terry L. Levinsky, and accept service of the Consolidated Complaint in Divorce, which was delivered to me on August 20, 2007. Mary A. Etter Dissinger Attorney for Defendant Superior Court ID #27736 28 N. 32nd Street Camp Hill, PA 17011 (717)975-2840 (717)975-3924 - fax r.~ c° T.Jr= ~, '~ ~ !" Cr.S _ _ {w~ ~ P~ti; l C? r :.3 L `' Y t .' ,...- ~ ~~ n' ~.~ f ~~ ~ ~ ". i+ ~m :~ w N ~' ~- .~ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-04673 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HARMAN-LEVINSKY KELLI S VS LEVINSKY TERRY L R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT LEVINSKY TERRY L but was unable to locate Him to wit: in his bailiwick. He therefore deputized the sheriff of LANCASTER serve the within NOTICE COMPLAINT DIVORCE County, Pennsylvania, to On August 29th 2007 this office was in receipt of the attached return from LANCASTER Sheriffs Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 DEP. LANCASTER CO 53.17 POSTAGE .58 90.75 00/00/0000 SAMUEL ANDES So anew .,,,.--° f~,.~X~,``,~„~, i' <r• Y~i . Thomas Kline (~ I Sheriff of Cumber and County `7"" of dL1 ~~ Sworn and subscribe to before me this day of A.D. ~. . ,~. ..,. T .~ ,. ~ _ .... ,.-,.._ ~ ., '~~ ~ / ~~~~ f ,, ~ _ SHEF~IFF'S OFFICE H 50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 176th-3480 • (717)299-8200 n SHERIFF SERVICE ~; . PROCESS RECEIPT, and AFFIDAVIT OF RETURN ~.~: t P~Atfw~TLFF/S/ 2 COURT NUMBER - - ~~~ Kelli S. Harman-Levinsky 07-4673 civil, x 3. OEFENOANT/S/ 4 TYPE OF WRIT OR COMPLAINT ' Terry L. Levinsky Notice & Ccmplaint in Divorce ~RVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION. ETC.. TO BE SERVED. ^` Terry L. Lpvinsky 6 ADORE5S (Street or RFD, Apartment No., City, Boro, twp., State and ZIP Code) ~lT ~i25 Washington Stres°t Coltmbia, PA 7. INDICATE UNUSUAL SERVICE: D DEPUTIZE D OTHER Clmberland -- Now, August 20 , I, SHERIFF OF ~ COUNTY, PA., d ±drl(putize the S Lancasker Coultry to execute this Wrirr,~j~~~reof Iri to law. This deputation being made at the request and risk of the plaintiff. _ __ _ ,_ __ Ctmberland Please mail return of service to Cumberli~d County Sheriff. Thank yc~. NOTE ONLY A-KICAKE ON WRIT OF EXECUTION: N.a. WAItfER OF WATCHMAN -Any deputy aheriH levying upon or attaching any property under within writ may Leave same without a watchman, in custody of whomever is found in possession, attar notifying person of levy or eHachment, without liability on the part d such deputy or the et-erilf to arry plaintiff herein far any Toss, deatructian or removal of any such property before sheriff's sate thareof. 1. NATiN1E of ATTORN$1' or otfrar ORIOIN TOR 10. TELEPHOhIE NUMBER t t .GATE SAMUEL L.ANDES, ESQ. 717-761-5361 8/7/07 t2. s1!'<Ilt! NOTICE OF SERVICE COr'tr TO NAME AND ADORE$$ BELOW: (This area must be completed if notice is to bi mailed) P.O. BOX 168 LEMOYNEr PA. 17043 13. I acknowledge receipt of the writ ~ NAME of Authorized LCSO Depuy or Clerk 14. Date Received 15. ~ExpirationlHearing date or complaint as indicated above. JA C MICCIC H E 390-23Q9 8/7.3/07 16. I hereby CERTIFY and RETURN that eve personally served, D have legal evidence of service es shown in "Remarks", ^ have executed as shaven in "Remarks",the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, cor- poration, etc.. at the address inserted below by handing a TRUE and ATTESTED COPY thereof. t 7. D I hereby certify and return a NOT FOUND bscau§e I am unable to locate thr~ individual, company, corporation, etc., named above. (See remarks below) 18. Name and title o1 individual served (if not shown above) (Retetionship to Defendent- 19. ~PbService Sea Rsmerke Below (Na 30) 20. Address of where served (complete only if different than shown above) (Street or RFD, Apartment No., City, Boro. Twp. 21 Date of Service 22 Time State and Zip Code) ~~ f~r .~IN~. pM ~i! E 23. A T8 ©ata Mills Di .Int. Data Mills Dep. Int. Data Milaa Oap. Int. Data Miles Dap. Int. Data Miles Dap. Int. ~~ 2e. Advance Coals 25. Service Coats 26. Notary Cert. 27. Mil agaJPost eJN.F. 28 Total Cos 29 T euE eN1 REFWtD t 150.00 42.50 t 3V. IttMAHK,: S.T.A. 31. AFFIRMED and subscribed to before me this 31. day of C~7cxlagr ga ~~ Merl ~ I as u~~ ~~ Kelli S. Harman-Levinsky . Plaintiff vs. . Terry L. Levinsky . Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION N0. 07-4673 IN DIVORCE PETITION FOR LEAVE TO WITHDRAW AS COUNSEL And now comes Mary A. Etter Dissinger, Esquire, respectfully requesting this Honorable Court to grant her request for Leave to Withdraw as Counsel for Defendant and in support of that avers as follows: 1. Petitioner is Mary A. Etter Dissinger, Esquire, of Dissinger & Dissinger, Attorneys at Law, who currently represents Defendant in the above action. 2. Defendant is Terry L. Levinsky. 3. Defendant hired Petitioner to represent him as counsel on August 20, 2007. 4. The Honorable J. Wesley Oler, Jr. has signed an Order for Custody in this matter on December 19, 2007. (See Exhibit "A" attached) 5. Defendant has not complied with the contract/fee agreement with Dissinger & Dissinger requiring timely payment for services rendered, which he signed on August 20, 2007. 6. Defendant has not been cooperative in assisting Petitioner, her staff, or the Domestic Relations Office in rescheduling several support matters, even for the conference scheduled at Defendant's request and for Defendant's benefit. 7. Defendant does not return Petitioner's, or her staff's, telephone messages. 8. Defendant does not respond to Petitioner written requests for Defendant to contact Petitioner regarding his case. 9. Plaintiff's counsel has been notified of Petitioner's intent to withdraw and has no objections to Petitioner's withdrawal as counsel of record. Wherefore, Petitioner requests that she be granted permission for Leave to Withdraw as Counsel for Defendant. Respectfully submitted DISSINGER & DISSINGER ~~!~~ Mary Etter Petitioner Supreme Court 28 N. 32nd St Camp Hill, PA (717)975-2840 (717)975-3924 -~ /~- Dissinger, Esq. ID #27736 reet 17011 - fax _-- _ . ___.r , ' .~ ~, - a ' `^ '1'1/R~.Y ~.. LEViNSICY )N Ti~~~ C4'tJ~.T C41v~1~(~N i'L)~AS t)~ l~'l~ntiff CU1Vll~~RLAND CC)UNTY, }~EM~ISYLVA1~IA vs. ~'7-~` CIVi~, ACTCJ~ LAVA _ i~L,LI S. HARl~1AN-I.~V~'S~~' 'i~cfendarrt IIV CCJSTCU'Y h k A~~ P''~, t~s ^.~.~~ day of -~~~ Z00', upon c~-id+,~ati~n ofthe attached Custody Gortciliatan Report, it is ordered directed ~s follows: l: Tl lr ~tder o~'this Count elated November 9, 2447 shall c~atianue in effect as modiFed by ~ Qrd~r. ~ 2. l~eging inax~iediately ~ continuing ot~ a7n o4i~ bads, vv~i~ the Father works on the day shaft itn~edately ~arece+dimg his ttivo {~) days ofF, the Father's period of partii~al custody shall begin alter work on tht last flay of work rr than on his first cry off. Beginning l~ebruary 1, 20Q8, and co~~~ on a~ ortgoang basis, when the Father has tvvt~ (2) days off vwokk in~m~dily fallow~cl by a ran to ~v~ck on ~e night shift (which does rat fall on ~ Monday) the Father:shali retain custody of tote Cl~il~l tt~nh tt~ day on which h~e retu~s co w~rk,dn the night shin, ~uvhen the Motlter shall pick u~ a Cl~ld at Ray Lcvimsky's rasi~ce at $;40 p.na. ~n the e~rent tl~ Fa~her'$ retuaa~ to work on the rtit ~i~ falls on a Monday, the ~xchan~e of cost©dy shall be on the pz~+cedng Sunday. 3: Amer impletnenti~r~g the ~cpar~ons of t~1e Fatl~r's periods of partial custody provided in this, Order !Qr a period cif at lea$t t-~vn (2} marttths, cnunl for either party rrtay coa~tact the conciliator to scl~da ~ ~ti custordy conealiataon confvsence to review the cusfiotiy schedule, if necessary. 1 ~. unless otherwise agreed between the parties, all exchanges of custody shall talcs piece at 5:f p:r~. 5. The l~a~er ~n,~ay retx-~ove the Child from the local area during has periods of custody td fia~#ce trigs or ~iit ~ie~ds aatd family in Clinton County or elsewhere. In the event either party intends to rcrnove the Child from t~ l~oeal area for extended period j14 hours or mpre), that parent shall . provide advance notice to the other parent t~f the eontact information for the Child. EXHIBIT nAn ~~ 6. This Order is enteral pursuant to an agreement of the paa~ties at a custody conciliation conference. The parties may modify the provisions of this Order bry mutual consent. In the absence of mutual consent, the terms of ~ Order shat! cc~~l: BY THE COURT, r. ey lea- J, cc: Mary A,. Etter Dissin~er, .Esquire -Counsel for Father Samuel L. Andes, Esc~sre - Counsel for Mother ~~~~ ~CJF~1~ Fr~~i~+~ ~~~.~t~~1u ~~ r~ati~~ny ~vfi~~t8of, i hers u~i~ ~sf my ~~~ .,L~ t~t~ ss~i of s~}d at Cartts~. ~ f ~~~,~ ~y Kelli S. Harman-Levinsky Plaintiff . vs. Terry L. Levinsky Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION N0. 07-4673 IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon Defendant, Terry L. Levinsky, and upon Samuel Andes, attorney for Plaintiff, by First Class United States mail addressed as follows: Mr. Terry L. Levinsky 625 Washington Street Columbia, PA 17512 AND Samuel L. Andes, Esq. 525 N. 12`h Street P.O. Box 168 Lemoyne, PA 17043-0168 Date: ~S ary Etter Dissinger, E q. • ~lAR d 4 20D8 ~' y Kelli S. Harman-Levinsky Plaintiff vs. Terry L. Levinsky Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION NG. 07-4673 IN DIVORCE RULE TO SHOW CAUSE AND NOW, this -,~z-f~- day of ~~~ ~,-~ 2008, upon °eview of the foregoing Motion, a Rule is hereby entered against the Defendant, Terry L. Levinsky, and Plaintiff's attorney, Samuel Andes, to show cause why the Court should not enter an Order granting the Petitioner for Leave to Withdraw as Defendant's Counsel. Rule returnable 10 days from the date of the service hereof. Dissinger, Esq.- 28 N. 32°d St., Camp Hill, PA 17011 Mr. Ter:cy L. Levinsky - 625 Washington Street, Columbia, PA 17512 ~uel L. Andes, Esq. -525 N. 12~" Street, P.O. Box 168, Lemoyne, PA 17043-016 ~S ~,~~~~ Di,~ribution: ary A. EtterA. Etter o~ ~% BY THE COURT: rn N ,~"° f.'~ J c~ .~ ~: ~~ a ~? ~~ ~ M4. ~t~~ ~ r ~ r Kelli S. Harman-Levinsky . Plaintiff . vs. . Terry L. Levinsky . Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION N0. 07-4673 IN DIVORCE MOTION TO MAKE RULE TO SHOW CAU5E ABSOLUTE AND NOW, comes Petitioner, Mary A. Etter Dissinger, Esq., and respectfully moves this Court to make absolute the Rule to Show Cause which was issued in the above-captioned matter on March 5, 2008, and in support states the following: 1. Petitioner, Mary A. Etter Dissinger, Esq., filed a Petition for Leave to Withdraw as Defendant's Counsel. 2. On March 5, 2008, this Court issued a Rule on Defendant, Terry L. Levinsky, and Plaintiff's attorney, Samuel Andes, to show cause why Petitioner should not granted Leave to Withdraw as Defendant's Counsel, returnable ten (10) days from date of service. 3. On March 7, 2008, Petitioner, counsel for Defendant, caused a copy of the Rule to be served on Defendant, Terry L. Levinsky, and Plaintiff's attorney, Samuel Andes by United States Mail delivery. 4. Defendant, Terry L. Levinsky, and Plaintiff`s attorney, Samuel Andes have not filed any objection with the Court to Petitioner's petition to date, and Attorney Andes has sent Petitioner a letter dated March 13, 2008, stating that he will raise no objections. (See Exhibit "A" attached) WHEREFORE, Petitioner, Mary A. Etter Dissinger, Esq., requests that this Court make the Rule To Show Cause absolute and grant the Petition For Leave to Withdraw as Defendant's Counsel. Respectfully Submitted, DISSINGER AND DISSINGER ~, Mary A. Etter Dissinge Petitioner Supreme Court ID # 27736 28 N. 32nd Street Camp Hill, PA 17011 (717) 975-2840 (717) 975-3924 - fax SAMUEL L. ANDES ATTORNEY AT LAW 525 NOETB Th*SLPTH STREET xAlLtxo eaaasss: P. O. BOX I69 LHMOYxE. PA 17043.0186 H•M.AIL: LpvMnaespsW.com Mary A. Etter Dissinger, Esquire 28 North 32"d Street Camp Hill, PA 17011 RE; Terry L. Levinsky Dear Mary: P. O. HOX 168 LEMOYNE, PENNSYLVANIA 170.43 13 March 2008 THLHPIIONB (717) 76l•63A1 FAX (7l7) 76!•!436 My client and I do not oppose your petition for leave to withdraw as Mr. Levinsky's attorney and I will not be filing anything to oppose your petition. You are free to attach a copy of this letter to your motion to make your Rule absolute. Sincerely, amh cc: Ms. Kelli S. Harman-Levinsky e! L. Andes EXHIBIT !l All Kelli S. Harman-Levinsky Plaintiff . vs. . Terry L, Levinsky . Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION N0. 07-4673 IN DIVORCE CERTIFICATE OF SERVICE I, Mary A. Etter Dissinger, Esquire, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon Defendant, Terry L. Levinsky, and upon Samuel Andes, attorney for Plaintiff, by First Class United States mail addressed as follows: Mr. Terry L. Levinsky 625 Washington Street Columbia, PA 17512 AND Samuel L. Andes, Esq. 525 N. 12t'' Street P.O. Box 168 Lemoyne, PA 17043-0168 Date: ~ S C ~.. Mary A. .Etter Dissinger, Esq. ~ ` ~ r % ' -C1 a.~: '-"' ~} Z El ~~, ~ '~ C; ~'~ ~: C.~ .. ~,~ c.; ~ ~. ' r.. i ~.~ '. 4 4 "~ •^r ». ~~.. e ~ ~ as zoos ~+` Kelli S. Harman-Levinsky IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION Terry L. Levinsky N0. 07-4673 Defendant IN DIVORCE ORDER AND NOW, this ~~ day of ~~, 2008, upon consideration of Petitioner, Mary A. Etter Dissinger's motion, it is hereby ORDERED that the Rule which was issued on Defendant, Terry L. Levinsky, and Plaintiff's attorney, Samuel Andes, in the above-captioned matter on March 5, 2008, to show cause why Petitioner should not be granted Leave to Withdraw as Defendant's Counsel is made absolute, and that Petitioner, Mary A. Etter Dissinger's Petition for Leave to Withdraw as Defendant's Counsel is granted. BY THE COURT: -~ y >,~~ ;~_ ,:_. _.... 3~,'y .3 f ~ w ~J ,-~ <~.. s ~- E''•.j KELLI S. HARMAN-LEVINSKY, Plaintiff vs. TERRY L. LEVINSKY, Defendant IN THE COURT OF COMMON PLEAS OF CUMB'~ERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4b73 IN DIVORCE PETITION FOR EMERGENCY RELIEF AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and petitions the Court for emergency relief in this matter, based upon the following: 1. The Petitioner herein is the Plaintiff. The Respondent is the Defendant. 2. During the marriage the parties acquired, in their joint names, a 2000 Lexis 470 automobile. They purchased the vehicle with funds which were borrowed, however, in Plaintiff's name alone. 3. After the parties separated, Plaintiff retained possession of the vehicle and made payments on the loan which encumbered its title. 4. At various times since the parties' separation, Defendant agreed that he would pay the loan owed to the Pennsylvania State Employees Credit Union which encumbered the title to the vehicle if he could have possession of it. Defendant, however, refused to sign any written agreement to formalize that offer. Plaintiff advised Defendant that she would not allow him to have possession or use of the vehicle unless he agreed, in writing, to be responsible to pay the PSECU loan. 5. On 19 August 2008, without the prior knowledge or consent of Plaintiff, Defendant came to Plaintiff s home, while Plaintiff was away, entered her home, took the keys to the Lexis vehicle, and removed the Lexis vehicle. Defendant has refused to return the vehicle since that time. -1- 6. Plaintiff wishes to resolve this matter either by selling the vehicle to pay off the loan which encumbers it, by transferring the title to the vehicle to Plaintiffls name alone and Plaintiffbeing responsible to pay the PSECU loan, or by transferring the title to the vehicle to Defendant and him satisfying the PSECU loan, or otherwise obtaining her release from that obligation. 7. Plaintiff believes that Defendant does not concur in the relief requested in this petition. 8. No Judge in Cumberland County has previously entered orders in this action to Plaintiff's knowledge. WHEREFORE, Plaintiffprays this Court for the following relief: A. Direct the Defendant to immediately return the possession and keys of the 2000 Lexis 470 automobile to Plaintiff and sign the title and other documents necessary to transfer ownership of the vehicle to Plaintiff; or B. Direct that Defendant obtain Plaintiff s release from the debt owed to PSECU which encumbers the title to the vehicle in exchange for Plaintiff transferring the title to Defendant's name alone; and C. Such other relief as the Court deems appropriate or equitable. P.O. Box 168 Lemoyne, PA 17043 717-761-5361 -2- Attorney for Plaintiff I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. ~, ,r Kelli S. arman-Levinsky -3- CERTIFICATE OF SERVICE I hereby certify that on 3 gp~p ~ ~j, ~,(' 2008, I served a copy of the foregoing document upon counsel for Defendant by U.S. Mail, postage prepaid, addressed as follows: Mark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 Samuel L. An Attorney for Plaintiff Supreme Court ID 17225 P.O. Box 168 Lemoyne, PA 17043 (717)761-5361 -4- `~ ' =r t T ,_~ .a a ~~ - ,a; ~_ ;r.,. t J .+% ::t KELLI S. HARMAN-LEVINSKY, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION -LAW NO. 0?-4673 TERRY L. LEVINSKY, Defendant IN DNORCE ORDER OF COURT AND NOW this _ day of , 2008, upon consideration of the attached petition, a hearing is hereby scheduled, to beheld before the undersigned in Court Room No. ~[ of the Cumberland County Court House, Carlisle, PA, commencing at ~' d d o'clock ~.m., on the ~~- day of , 2008. Distrib ion: azk F. Bayley, Attorney for Defendant, 1? West South Street, Carlisle, PA 17013 / Samuel L. Andes, Attorney for Plaintiff, P.O. Box 16$, Lemoyne, PA 17043 ~,~~~a. ~g/~o%e I BY THE COURT, .~ ~ ~ A ~ .1:~ (l r~.f,y .. t: U ~ . ~ ; [ ~ ~~qs~ 0 i ~~S ~~~:Z ~~ M~- t ~ .•. i ~~~ -,~,~_~_:~ ,-t,4-; ~f~ KELLI S. HARMAN-LEVINSKY, Plaintiff vs. 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4673 TERRY L. LEVINSKY, Defendant IN DIVORCE STIPULATION AND NOW come the above-named parties, by their counsel who execute this Stipulation on their behalf and with their authorization, and stipulate and agree that the court should enter the attached order to resolve the matters raised in the Plaintiff s Petition for Emergency Relief relating to possession and title to the 2000 Lexus 470 automobile. 2°1 O ~~" ~g Date ar ~ f ~ ~. ~~~ .~ ~, ;,~. Date L. An+ for P Mark F. Bayley Attorney for Plaintiff . ~ NOV ~ 3 20Q8 (~ KELLI S. HARMAN-LEVINSKY, Plaintiff vs. TERRY L. LEVINSKY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4673 IN DIVORCE ORDER FOR.~.1D. ELIVERY AND TRANSFEl!R OF MOTOR VEHICLE AND NOW, this S ``~ day of ~1 a v c •--~b e3 , 2008, based upon the stipulation of the parties, and in response to Plaintiffs Petition for Emergency Relief, we hereby order and direct as follows: 1. The Defendant Teny L. Levinsky shall deliver possession of the 2000 Lexus 470 automobile to Plaintiff within ten (10) days of the date of this Order. 2. Within ten (10) days of the date of this Order, the Plaintiff and Defendant shall meet at the credit union which holds the encumbrance on the title to the 2000 Lexus 470 automobile and execute any and all documents required to transfer the title to that vehicle to the Plaintiff alone. 3. This Order resolves the matter raised in the Plaintiff's Petition for Emergency Relief upon the completion of the above action by the parties. Distribution: (Samuel L. Andes, Esquire (Attorney for Plaintiff) 525 North 12"' Street, P.O. Box 168, Lemoyne, PA Mark F. Bayley, Esquire (Attorney for Defendant) 17 West South Street, Carlisle, PA 17013 ~-{~ t~~ S vYia t 1~--~ i ~ a~ ~~ 17043 Rf~ .,~ ' ~ ~) ,a`." ~1.- i t ; 1;.~. C3~"s _ .` ; i -'"' >~,~. ~` a ~. 1~ %.~ ~.-?. 1 '" `. r-~~ w { y'fL4~ ~ ~,") 1" ~ 1...~ KELLI S. HARMAN-LEVINSKY, Plaintiff vs. TERRY L. LEVINSKY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4673 CIVIL TERM IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about ~ ~ n~ ~ (, 2007, and have continued to live separately 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: LLI S. HARMAN-LE SKY 1 SL.I«t.J iV... ~~~~ ~';~~ t ~~ ~~ i ~~'• v ~~ ~ _ : ;'" r '. .... ~ KELLI S. HARMAN-LEVINSKY, Plaintiff vs. TERRY L. LEVINSKY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL\/ANIA CIVIL ACT"ION -LAW NO. 07-4673 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 7 August 2007 and served upon the Defendant on or about 21 August 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony,, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce clecree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true ,and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~ 30 o~j Dated r K LLI S. HARMAN-LEV ~I?JSKY I~~ 1 ~~~Ii '{fu~l'•~IA`~~ h:n 2~~9 kl.~L -2 ~i~ dJ• ^~ KELLI S. HARMAN-LEVINSKY, ) Plaintiff ) vs. ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY', PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4Ei73 ~' r TERRY L. LEVINSKY, ) t' :~ _r Defendant ) IN DIVORCE { ~ ~~ `~ ~ " ~~ [tea - ~, AFFIDAVIT OF CONSENT ~ ==' -_~_ 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code vvas file~on ~+ August 2007 and served upon the Defendant on or about 21 August x;007. ,-_' cJ 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF T'HE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I ,understand that I ~vlll not >ve d.verced ~ur_t:l a ~?i:'nrra de~rt'e :S entered b~~ *he CO',:rt and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.. Section 4904 relating to unsworn falsification to authorities. r.? // /` r ~, Dated: TERRY L. VTNSI~_Y ,,.'~ ~t~r--~ ~; - ;~ ~~ t~;_ ~, + ~'7.'n~ `~ L::. ~ ((}} r ' _ y~ , 11' i `l. ~; KELLI S. HARMAN-LEVINSKY, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF= CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW TERRY L. LEVINSKY, Defendant NO. 07-4673 IN DIVORCE TO THE PROTHONOTARY: PRAECIPE Please withdraw all claims for economic relief previously filed on behalf of the Plainitff in the above matter. Date: ~ 3 a o q ~m el L. les Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street: P.O. Box 168 Lemoyne, Pa 17043 (717) 761-5361 i-1L~C: ,.~,, ~F _ ~ r rl ~ 2~~9,1;~- --~ ~i,~ ~~~ w ~ ~' t ~`1 ~.1 KELLI S. I-IARMAN-LEVINSKY, ) IN THE COURT OF COMMON Plaintiff ) PLEAS C>F CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION -LAW NO. 07-4673 TERRY L. LEVINSKY, ) Defendant ) IN DIVO:E~CE TO THE PROTHONOTARY: PRAECIPE Please withdraw all claims for economic relief previously filed by me or on my behalf in the above matter. ,_ rte} Date: ~, ~o O ~ ~.~ Terry L. Le FlLF[~ + ; ~~~ F f)~ ~Iw ;,~ ,T }~ i ,:~?~ Z~~~ VLis _2 17 ~V~ t_ V ~ ~ 1 i r I f ` KELLI S. HARMAN,LEVINSKY, Plaintiff vs. TERRY L. LEVINSKY, Defendant IN THE COURT OF COMMON PLEAS OF (:UMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO 07-467c1 CIVIL TERM IN DIVORCE: PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the Complaint: Acceptance of Service indicating service on or about 20 August 2007. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: 30 June 2009 by Defendant: 30 June 2009 (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Defendant's Affidavit upon the Respondent: 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 30 June 2009 and filed contemporaneously with this Praecipe. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 30 June 2009 and filed contemporaneously with this praecige Date: 30 June 2009 gy ~ Samuel L. Andes Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF KELLI SHARMAN-LEVINSKY :CUMBERLAND COUNTY, PENNSYLVANIA V. TERRY L LEVINSKY NO. 07-4673 CIVIL TERM DIVORCE DECREE AND NOW, ~ ~ d o , it is ordered and decreed that KELLI SHARMAN-LEVINSKY ,plaintiff, and TERRY L LEVINSKY bonds of matrimony. defendant, are divorced from the 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, 7 - .~~ -~f` X10 tiw~-~-~, ~` ~~ _.