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Home My WebLink About07-6580Angela Sue Micklo, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE, EQUITABLE DISTRIBUTION, Jeffrey S. Micklo, : ALIMONY Defendant :NO. 07- CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, Cumberland County Courthouse, Carlisle, Pennsylvania. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 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. Angela Sue Micklo, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE, EQUITABLE DISTRIBUTION, Jeffrey S. Micklo, : ALIMONY Defendant : NO. 07- G S Pd CIVIL TERM DIVORCE COMPLAINT WITH EQUITABLE DISTRIBUTION AND ALIMONY COUNTS The plaintiff, Angela Sue Micklo, by her attorneys, the Family Law Clinic, sets forth the following causes of action in divorce, equitable distribution and alimony: COUNT ONE DIVORCE UNDER 23 Pa.C.S. §63301(c) AND 3301(d) OF THE DIVORCE CODE 1. 2. 3. 4. 5. 6. 7. 8. Plaintiff is Ms. Angela Sue Micklo, who currently resides at 139 S. Pitt Street, Carlisle. Plaintiff has been a resident of Cumberland County since December 2004. Defendant is Mr. Jeffrey S. Micklo, who currently resides at 129 Channel Drive, Carlisle, PA 17013, since December 2005. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. Plaintiff and Defendant were married on May 12, 2001, at Mount Holly Springs, Cumberland County, PA. Plaintiff and Defendant have lived separate and apart since on or about December 2005. There have been no prior actions for divorce or for annulment between the parties. The marriage is irretrievably broken. 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. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce dissolving the mamage. COUNT II EQUITABLE DISTRIBUTION 9. Plaintiff repeats and realleges paragraphs one through eight. 10. Plaintiff and Defendant have acquired property during their marriage, including, but not limited to: a) Proceeds from sale of house and property at 119 Walton Circle, Ickesburg, PA b) Two cars, a Pontiac and a Dodge C) Wedding band, Diamond Ring, Diamond Earrings WHEREFORE, Plaintiff requests the Court to enter a decree dividing the marital property equitably between the parties and such other relief as the Court deems just. COUNT III ALIMONY 11. Plaintiff repeats and realleges paragraphs one through ten. 12. Plaintiff requires support to adequately maintain herself in accordance with a reasonable standard of living. 13. Plaintiff as a result of her current medical condition is unable to maintain employment outside the home. 14. Defendant is financially able to provide for his reasonable needs and the reasonable needs of the Plaintiff. WHEREFORE, Plaintiff requests the Court to enter an award of reasonable alimony and such other relief as the Court deems just. Respectfully Submitted, DATE (0 I Scott Weber Certified Legal Intern ROB EAT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date.? Plaintiff Angela S Micklo C 7 - , -? Angela Sue Micklo, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE, EQUITABLE DISTRIBUTION, ALIMONY Jeffrey S. Micklo Defendant : NO. 07- (210 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Angela Sue Micklo, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date ?? ' c} Respectfully submitted, Scott Weber Certified Legal Intern ROB T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 717-243-3639 ? ? ?^ f""? 6'61 ??.- _???: - ? 7 _ .. C; :7 ?,,: .,, ('t7 Angela Sue Micklo, IN THE COURT OF Plaintiff COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW : IN DIVORCE, EQUITABLE DISTRIBUTION, Jeffrey S. Micklo, : ALIMONY Defendant NO. 07 - 6580 CIVIL TERM CERTIFICATE OF SERVICE I, Scott Weber ,Certified Legal Intern, Family Law Clinic hereby certify that I served a true and correct copy of the Divorce Complaint on Jeff , Drive, Carlisle, PA, by depositing ret' S. Micklo, residing at 119 channel g a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon recei t by Jeffrey Micklo, on the 6th day of November, 2007 as evid p enced by the attached green card. N ?$ F z m } ? ?? C w o _a a E? L 0 m 0Ao - >_ to m ?W cc ?? m p r5 1 1 a 7 L 2 - 0 •- ?- r?°po-L- U Y U .0M.a C MID V ? -4- CO C5 COL N ? 3r m $ r L+t+ Q C L G CL -0 Scott Weber Certified Legal Intern Megan Riesmeyer, Esq. Supervising Attorney a ir E U QI U a r- m r- Ln ti m .A nj m O O O 0 Er m 0 0 0 r- N i r CD M (d 3 s `U) N FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ?: ? ? _` ?=? ? 4LL?:} '? Angela Sue Micklo, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE, EQUITABLE DISTRIBUTION, Jeffrey S. Micklo, : ALIMONY Defendant : NO. 07-6580 CIVIL TERM INVENTORY OF ANGELA SUE MICKLO Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct, to the best of her knowledge, information, and belief. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Plaintiff ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (x) 1. Real Property (x ) 2. Motor Vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit (x ) 5. Checking accounts, cash (x ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities (x) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventories, royalties (x) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits - severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans (x ) 18. Pension plans (indicate employee contribution and date plan vests) (x ) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits ( ) 24. Debts due, including loans, mortgages held (x ) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Description Names Of Number Of Property All Owners 1. property in Bedford, PA (bought prior to Jeffrey Micklo but held throughout marriage) 2. Pontiac Bonneville; 2001 Dodge Ram Jeffrey Micklo Winnebago 5. Checking account - value unknown Jeffrey Micklo 6. Savings account - value unknown Jeffrey Micklo 11. Gifts to Jeffrey and Angela: furniture, grandfather clock, double door refrigerator, $20,000 cash Gifts to Angela from Jeffrey: diamond engagement Ring, wedding band, diamond earrings 14. baby books, paperwork regarding jewelry, Jeffrey and Angela contents of safe, Micklo 18. Jeffrey Micklo's pension Jeffrey Micklo 2 19. Jeffrey Micklo's retirement plan Jeffrey Micklo 25. couch, loveseat, end tables, lamps, coffee tables, Jeffrey and Angela dining room table, refrigerator, televisions, beds, Micklo dressers, guns, bows, gun cabinets, dishes, apple dish set PROPERTY TRANSFERRED Item Description Date Of Person To Whom Number of Property Transfer Consideration Transferred 1. marital residence - Dec. 2004 $115,900 119 Walton Circle, Ickesburg, PA LIABILITIES Item Number Description of Property Names Of Names Of All Creditors All Debtors NONMARITAL PROPERTY Item Number 14. Description Reason For Exclusion of Property Owner from Marital Property diamonds and jewelry Angela Micklo belonged to Plaintiff prior to the marriage Plaintiff reserves the right to correct and/or supplement this Inventory to the extent that 3 Angela Sue v Jeffrey S. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DIVORCE :No. 07-6580 CIVIL TERM To The Please 2007 at the ab April 4, 2008 PRAECIPE TO WITHDRAW ALIMONY CLAIM the claim for Alimony from the Divorce Complaint filed on October 30, ,ned docket. VZZ221? L:J2? Rebecca Faulkner Certified Legal Intern r Meg iesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 '4a ?,. ? .? ?>-. ,:._ ?-: " . ?7 .? r ? ; ? ? : ` S ACM f ?..T '-^{ Angela Micklo, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Jeffrey Micklo, Defendant :NO. 07-6580 CIVIL TERM AFFIDAVIT OF SERVICE I, Rebecca Faulkner, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Praecipe to Withdraw Alimony Claim, on Michael Scherer, Esquire, at 19 West South Street, Carlisle, PA 17013, on April 11, 2008, by placing a copy of the same in the United States mail. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. 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: ?__?L X08 Rebecca Faulkner Certified Legal Intern ?? ?.a / 5?.,,,7 y-» f..'7 ??,./ :.. ??A ' L ...: ?"` ( - ~ '' ?...?? w ? .. F:Y ?? ANGELA SUE MICKLO, Plaintiff V. JEFFREY S. MICKLO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6580 CIVIL ACTION - LAW IN DIVORCE, EQUITABLE DISTRIBUTION, ALIMONY PETITION TO MERGE DIVORCE COMPLAINTS The petition of Angela Micklo, by her attorneys the Family Law Clinic, respectfully represents the following: 1. On December 2, 2005, Jeffrey S. Micklo filed a Divorce Complaint, by and through his attorney Michael A. Scherer, Esquire, naming himself as plaintiff and Angela S. Micklo as defendant. This matter was docketed at No. 2005 - 6218. Mr. Micklo's Divorce Complaint contains three counts: Count I - Divorce, Count II - Indignities, and Count III - Custody. 2. On October 30, 2007, two years having elapsed, the Family Law Clinic mistakenly filed a Divorce Complaint on Angela S. Micklo's behalf, naming Ms. Micklo as plaintiff and Jeffrey S. Micklo as defendant. This matter was docketed at No. 2007 - 6580. Ms. Micklo's Divorce Complaint contains three counts: Count I - Divorce, Count II - Equitable Distribution, and Count III - Alimony. 3. On April 10, 2008, Ms. Micklo, by and through her attorneys the Family Law Clinic, filed a Praecipe to Withdraw Alimony Claim. 4. At this time, both divorce complaints are active. 5. The Family Law Clinic has discussed this matter with Mr. Micklo's attorney, Michael A. Scherer, Esquire, and has obtained Mr. Scherer's consent to merge the two divorce matters, with all further actions to be filed to and under the caption of JEFFREY S. MICKLO v. ANGELA S. MICKLO, Docket No. 2005 - 6218. 6. No Judge has been assigned to either of these dockets. WHEREFORE, the Family Law Clinic respectfully requests that this Court merge the two divorce matters into one docket, with all further actions to be filed to and under the caption of JEFFREY S. MICKLO v. ANGELA S. MICKLO, Docket No. 2005 - 6218. The Family Law Clinic further requests that this Court preserve Ms. Micko's Equitable Distribution claim under the merged docket. Date: Q"11 ?ln cL ebecca Fa lkner Certified Legal Intern &WZ &i MEGAN RIESMEYER. Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: 72YZa L"- Z :,M} Rebecca F ulkner Certified Legal Intern CERTIFICATE OF SERVICE I, Rebecca Faulkner, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition to Merge Divorce on the following person by first class U.S. Mail, postage prepaid, this 7t' day of November, 2008, at the following address: Michael A. Scherer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 Rebecca Faull er Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 -?-., _ `r _{ ?t? ::- r . t- -. -' .. ?? i£. :,;. p ls`G ?, :; NOV 10 20080-, JEFFREY S. MICKLO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 6218 ? ANGELA S. MICKLO, CIVIL ACTION -LAW Defendant IN DIVORCE AND CUSTODY ANGELA SUE MICKLO, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007 - 6580 CIVIL ACTION -LAW JEFFREY S. MICKLO, : IN DIVORCE, EQUITABLE DISTRIBUTION, Defendant ALIMONY ORDER AND NOW THIS 1Y' day of November, 2008, it is hereby ordered that these two cases shall hereby be combined and all further actions shall be filed to and under the caption of JEFFREY S. MICKLO v. ANGELA S. MICKLO, Docket No. 2005 - 6218. By the urt Distributio is el A. Scherer, Esquire, counsel for Jeffrey Micklo F 1 ly Law Clinic, counsel for Angela Micklo y c r?{?' ?,? ti y??? ??' a?`` °'??d? .??,, ; r "w? ?' :??1t3 ,,?,K1?,ji?.w` ,r?,.-l1