Loading...
HomeMy WebLinkAbout07-6709 JULIE M. KRETZING, Plaintiff, V. GEORGE F. KRETZING, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - L 7O F IN DIVORCE CIVIL TERM 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 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 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 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. I JULIE M. KRETZING, Plaintiff, V. GEORGE F. KRETZING, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 6 )0? CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTIONS 3301(C) AND (Q OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Julie A. Kretzing, by and through her attorneys, Irwin, & McKnight, and files this Complaint in Divorce against the Defendant, George F. Kretzing, representing as follows: 1. The Plaintiff is Julie A. Kretzing, an adult individual residing at 208 Shughart Avenue, Boiling Springs, Pennsylvania 17007. 2. The Defendant is George F. Kretzing, an adult individual currently residing at 1060 Whispering Pines Drive, Kernersville, North Carolina 27284. 3. The Plaintiff and Defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on July 18, 1986, in Perry County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage between the two parties. By: Respectfully submitted, IRWIN & McKNIGHT Carlisle, Pennsy 3-3222 (717) 249-2353 Marc s A. fight, II11ms Supr e Court I.D. No. 25476 W t omfret Professional Bui 60 omfret Street Dated: November 2, 2007 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. 0, JU E A. KRETZING Date: November 2, 2007 JULIE M. KRETZING, Plaintiff, V. GEORGE F. KRETZING, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : 2007 - 6,70 Y CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Qy IE A. KRETZING Date: November 2, 2007 T) w Us W It W GI of -71 - r _ L?? 1' JULIE M. KRETZING, Plaintiff, v. GEORGE F. KRETZING, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 6709 CIVIL TERM IN DIVORCE PRAECIPE TO AMENDED CAPTION TO CURTIS R. LONG, PROTHONOTARY: Please amend the Plaintiff's name in the above caption as follows: JULIE M. KRETZING now amended to JULIE A. KRETZING Respectfully submitted, By: IRWIN & Marcus A. NsKddpt, III, 60 West fret Street Carlisle, P 17013 (717) 24 - 3 Supreme Court I.D-N-67725 Attorney for Plaintiff, Julie A. Kretzing Date: November 13, 2007 t-2 0- r; JULIE A. KRETZING, Plaintiff, V. GEORGE F. KRETZING, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007 - 6709 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA . . SS: COUNTY OF CUMBERLAND NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon George F. Kretzing, on November 11, 2007, by certified, restricted delivery ma him at 1060 Whispering Pines Drive, Kernersville, North Carolina 27284, with Number 7003 3110 0004 5768 1503. i. That the said receipt for certified mail is signed and attached hereto and made a! part hereof. I verify that the statements made in this affidavit are true and correct. I undlerstan4 that false statements herein made are subject to the penal 'es of 1/8 Pa. C. S. Section 4904, relatiig to unsworn falsification to authorities. ?l?/--a? 5 A.NcKNIGHT, III, ESQ for P intiff Date: November 13, 2007 M •. Zn a .n r` Ln ti?--- O Celled Fee C3 O ReWm (Endorsement Required) O Restricted Delivery r-:l (Endorsement Requi ra m Total Postage & Fees m C3 # Sw p [ MR. GWRG P- S`bee0WRIE-rinT0 r. Item 4 If Restricted Deli desired. X ? ¦ Print your crane and address on the reverse so that we can return the card to you. Bbyl C. Date of ¦ Attach this card to the beck of the mailpiece, F? - or on the front if space permits. ?iN`+"" 1 ` s ? Y e D. Is dWhWy addreee diMererd from l0em 1? 1. Article Addressed to: K YES, eater dellmy address below: ? No M[. (RORM F KMZIII<G IOW WHISPBSIIIG PIIIBS DBIYS MSVILLE-NC 27284 & Service Type 10 CerdW Mall ? B peas Math ? Registered tP r Ab" Rsos" for Msrcdrsnd l Irttwred MeN 4. F1utitolsrt lEkbu Fey tits 2. Article Nurnbw 7003 3110 0004 5768 1503 (?arrsf rer floor awMw Ys1 PS Form 3811, Fi wuwy 2004 Domallo Rout Rso IF "ttxace a¢ nr sao A . on C7 -t3 a 1 L r JULIE A. KRETZING, Plaintiff V. GEORGE F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6709 CIVIL CIVIL ACTION - LAW CUSTODY COMPLAINT 1. The Plaintiff is Julie M. Kretzing (hereinafter referred to as "Mother"), an adult individual who currently resides at, 208 Shughart Avenue, Boiling Springs, Cumberland County, Pennsylvania. 2. The Defendant is George F. Kretzing (hereinafter referred to as "Father"), an adult individual who currently resides at 1060 Whispering Pines Drive, Kernersville, Forsyth County, North Carolina. 3. The parties are the parents of a minor child, namely, Matthew T. Kretzing, born June 6, 1993 (hereinafter referred to as "Child") The child was born in wedlock The child is currently in the custody of Plaintiff. During the past five years, the child has resided with the following persons at the following addresses: Persons Residences Dates George Kretzing 1060 Whispering Pines birth-2005 Julie Kretzing Kernersville, North Carolina Brian Kretzing Michael Kretzing Julie Kretzing 8 Earl Street 2005-2007 Boiling Springs, Pennsylvania Julie Kretzing 208 Shughart Avenue 2007- Present Boiling Springs, Pennsylvania The natural father of the child is George F. Kretzing, currently residing at 1060 Whispering Pines Drive, Kernersville, Forsyth County, North Carolina. He is married to the Plaintiff. The natural mother of the child is Julie M. Kretzing, currently residing at 208 Shughart Drive, Boiling Springs, Cumberland County, Pennsylvania. She is married to the Defendant. 4. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides with the following persons: Names Matthew T. Kretzing Relationship Son 5. The relationship of the Defendant to the child is that of natural father. The Defendant currently resides with the following persons: Names Relationship Brian Kretzing Son Michael Kretzing Son 6. Defendant has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Defendant has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. While both parties were residents of the State of North Carolina, they signed a Separation Agreement and Property Settlement dated September 9, 2005, which provided that Mother would have primary physical custody of the child. The relevant portion of the September 9, 2005 Agreement is attached hereto as "Exhibit A." ti. 7. The best interest and permanent welfare of the child will be served by granting the parties shared legal and the Defendant primary physical custody. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: none WHEREFORE, Defendant requests your Honorable Court to grant him shared legal and primary physical custody of the child. Respectfully submitted, O'BRIEN, BARIC & SCHERER J / Date: 0'emu ? Michael A. Scherer, Esquire I. D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. This verification is signed by Michael A. Scherer, Esquire, Attorney for Defendant and is based upon the statements provided by Defendant, as well as documents reviewed by the undersigned as attorney for Defendant. This verification will be substituted and ratified by a verification signed by the Defendant who is presently unavailable to sign said verification. I undersigned that false statements herein are made subject to penalties of 18 Pa.C.S. §4904, relating to unsworn falsifications to authorities. 4111k .4.14 ? Mic ael A. Scherer, Esquire Dated: CERTIFICATE OF SERVICE I hereby certify that on the q111 day of , 2008, I, Andrea M. Barrick, of O'Brien, Baric & Scherer, did serve a copy of the Custody Complaint, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, Pennsylvania 17013 WL)nt" And rea . Barrick terms and conditions of this Separation Agreement shall be incorporated into any divorce decree subsequent to the terms and conditions contained herein or a part of any subsequent divorce judgment entered. SEVENTH: REAL PROPERTY. The parties presently own, as tenants by the entirety, a house and lot located at 1060 Whispering Pines Dr., in Kemersville, North Carolina. The parties agree that the husband shall have the exclusive use and possession of the home and shall be solely responsible for payment of the outstanding mortgage to BB&T. In addition, husband agrees to be solely responsible for the taxes, insurance and maintenance on the real property pending sale or refinance. Within twelve months of the signing of this Agreement, the house shall be placed on the market for sale, or shall the mortgage shall be refinanced by the Husband to secure the Wife's release from the mortgage. Whether the home is sold to a third party or refinanced by the Husband, Husband shall pay to the Wife the sum of $17,000.00 immediately after closing, this amount representing the Wife's share of the marital equity in the home. During the time that Wife remains obligated under the Note and Deed of Trust, Husband shall save and hold Wife harmless for any and all obligations arising from said real property including having signed the aforesaid Note and Deed of Trust. During the period Husband actually exercises the exclusive use and possession of the home, he shall be responsible for all maintenance, upkeep, repairs, and other liability however incurred without limitation, and agrees to'save and hold Wife harmless for the same. Wife agrees to forego any interest in the marital property immediately upon release of her obligation under the Note and Deed of Trust, and to execute for Husband a quitclaim deed relinquishing any and all interest in such property, and further to otherwise cooperate in good faith to expeditiously secure transfer of the property to Husband's exclusive ownership or to facilitate the sale to a third party. Husband shall be responsible for the costs. of the preparation of the deed, any closing costs, or costs associated with the refinance. EIGHTH: CUSTODY OF THE MINOR CHILDREN. Husband and Wife shall share the joint legal custody of the aforesaid minor children, namely: Brian Kretzing, born August 1, 1988, and Michael Kretzing, born March 8, 1990, and Matthew Kretzing, January 6, 1993.. Page 3 of 14 Exhibit "A" The parties will split physical custody of the children, as follows: a. The Husband shall have primary physical custody of Brian and Michael, and the Wife shall have primary physical custody of Matthew. b. Each parent shall be free to visit with the child or children in the physical custody of the other upon mutual agreement, but in the event the parties are unable to agree, the visitation schedule shall include the following: 1. Brian. Brian shall be free to visit with his mother as is mutually convenient for the parties and the child. 2. Michael. Michael shall visit with the Wife as follows: a. Christmas: In odd-numbered years, beginning with 2005, Wife shall have visitation with Michael from 8 p.m. the day after school lets out for the Winter Break from school until 1 p.m. on December 25. In even-numbered years beginning with 2006, Wife shall have Michael from December 25th at 1 p.m. until 6 p.m. the second day before the resumption of school. b. Thanksgiving: Wife shall have Michael every even-numbered year for Thanksgiving, beginning at 8 p.m. the Wednesday before Thanksgiving, and ending on the Friday following Thanksgiving at 1 p.m. C. Spring Break: In even-numbered years, Wife shall have Michael from 8 p.m. on the day school lets out for Spring Break until 8 p.m. the second day before the resumption of school. d. Summer vacation: In every year, Wife shall be entitled to a period of 14 consecutive days with Michael during the summer break from school, which shall not include any portion of the 7 days immediately prior to the resumption of school. Wife shall be entitled to designate when during the summer this visit shall occur and shall give notice to Husband at least 30 days before school ends. In the event she fails to give the notice required by this section, Husband shall be entitled to choose the visitation period, but Wife will nevertheless be entitled to her visit. Page 4 of 14 e. When visits begin and end. Wife's visitation shall be deemed to begin when Michael arrives at Wife's residence, and end when Michael arrives at the Husband's residence. The parties shall always have the right to vary from the visitation schedules as set out herein as they may mutually agree in the best interest of the minor children, and each of the parties agrees to negotiate and consult with the other parent in good faith with respect to such variances. Just as in the case of interruption of the regular custody schedule due to a holiday or summer vacation as set out above, any such variance will not alter. the rights of the parties under this agreement, nor affect the future application of the custody schedules, all of which shall continue in full force and effect immediately following any such variance just as if such variance had not occurred. Husband shall be responsible for Michael's transportation to Wife's residence at the beginning of each visit, and Wife shall be responsible for his return to Husband's residence. 3. Matthew. Matthew shall visit with the Husband as follows: a. Christmas: In even-numbered years, beginning with 2006, Husband shall have visitation with Matthew from 8 p.m. the day after school lets out for the Winter Break from school until 1 p.m. on December 25. In odd-numbered years beginning with 2005, Husband shall have Matthew from December 25`h at 1 p.m. until 6 p.m. the second day before the resumption of school. b. Thanksgiving: Husband shall have Matthew every odd-numbered year for Thanksgiving, beginning at 8 p.m. the Wednesday before Thanksgiving, and ending on the Friday following Thanksgiving at 1 p.m. C. Spring Break: In odd-numbered years, Husband shall have Matthew from 8 p.m. on the day school lets out for Spring Break until 8 p.m. the second day before the resumption of school. d. Summer vacation: In every year, Husband. shall be entitled to a period of 14 consecutive days with Matthew during the summer break from school, which shall not include any portion of the 7 days immediately prior to the resumption of school. Page 5 of 14 , . i Husband shall be entitled to designate when during the summer this visit shall occur and shall give notice to Wife at least 30 days before school ends. In the event he fails to give the notice required by this section, Wife shall be entitled to choose the visitation period, but Husband will nevertheless be entitled to his visit. e. When visits begin and end. Husband's visitation shall be deemed to begin when Matthew arrives at Husband's residence, and end when Matthew arrives at the Wife's residence. The parties shall always have the right to vary from the visitation schedules as set out herein as they may mutually agree in the best interest of the minor children, and each of the parties agrees to negotiate and consult with the other parent in good faith with respect to such variances. Just as in the case of interruption of the regular custody schedule due to a holiday or summer vacation as set out above, any such variance will not alter the rights of the parties under this agreement, nor affect the future application of the custody schedules, all of which shall continue in full force and effect immediately following any such variance just as if such_variance had not occurred. Wife shall be responsible for Matthew's transportation to Husband's residence at the beginning of each visit, and Husband shall be responsible for his return to Wife's residence. C. The parties shall confer together frequently regarding the health, development and well-being of the minor children, and shall promptly inform the other parent of any emergencies regarding the children as soon as it is safe to do so. d. Michael shall continue to be seen by a qualified counselor, and shall remain in the care of his doctor, Dr. Kathy Soldato. NINTH: CHILD SUPPORT. Husband shall pay without fail the sum of $ 41.00 per month to the Wife as child support for the support and maintenance of Matthew, to be paid directly to the Wife. Husband shall maintain medical insurance coverage for Matthew. The first payment shall be due on October 1, 2005 and shall be due the first of the month. Page 6 of 14 -r? a ". -gyp y? t W JULIE A. KRETZING, Plaintiff V. GEORGE F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6709 CIVIL CIVIL ACTION - LAW NOTICE TO PLEAD TO: Julie A. Kretzing c/o Marcus A. McKnight, III, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, Pennsylvania 17013 You are hereby notified that you have twenty (20) days in which to plead to the enclosed Defendant's Answer to Divorce Complaint and New Matter or a Default Judgment may be entered against you. O'BRIEN, BARIC & SCHERER Date: !W"- x 'Oe- Michael A. Scherer, quire I. D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Defendant JULIE A. KRETZING, Plaintiff V. GEORGE F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6709 CIVIL CIVIL ACTION - LAW DEFENDANT'S ANSWER TO DIVORCE COMPLAINT AND NOW, comes the Defendant, George F. Kretzing, by and through his attorney, Michael A. Scherer, Esquire, and respectfully replies to the Complaint as follows: 1. - 2. Admitted. 3. Denied. Defendant resides in North Carolina as stated in paragraph two of Plaintiffs Complaint. 4. - 8. Admitted. NEW MATTER 9. The most recent marital residence established by the parties was at 1060 Whispering Pines Drive, Kernersville, North Carolina. 10. The parties are governed by a Separation and Property Settlement Agreement dated September 9, 2005. 11. The September 9, 2005 Agreement states at paragraph "SIXTH" as follows: "Nothing herein contained shall be deemed to prevent either of the parties from maintaining a suit for absolute divorce against the other in any jurisdiction. In the event any such action is instituted, the parties shall be bound by all of the terms of this Agreement. The parties further agree that the terms and conditions of the Separation Agreement shall be incorporated into any divorce decree subsequent to the terms and conditions contained herein or a part of any subsequent divorce judgment entered. WHEREFORE, Defendant requests your Honorable Court incorporate the September 9, 2005 Agreement into the final Divorce Decree. Date: LI' g Respectfully submitted, O'BRIEN, BARIC & SCHERER Mic ae A. Scherer, Esquire I. D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. This verification is signed by Michael A. Scherer, Esquire, Attorney for Defendant and is based upon the statements provided by Defendant, as well as documents reviewed by the undersigned as attorney for Defendant. This verification will be substituted and ratified by a verification signed by the Defendant who is presently unavailable to sign said verification. I undersigned that false statements herein are made subject to penalties of 18 Pa.C.S. §4904, relating to unsworn falsifications to authorities. hffJhIel A. Scherer, Esquire Dated: h' ;' 0,07 CERTIFICATE OF SERVICE I hereby certify that on the Oft day of , 2008, I, Andrea M. Barrick, of O'Brien, Baric & Scherer, did serve a copy of the Defendant's Answer to Divorce Complaint and New Matter, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, Pennsylvania 17013 Andrea . Barrick ?_ r? a ?; t ` _ ? -?c? "?' t he ?(I ? }.. ,y ? {'?? ..? . ? ? _ i.. ' ? `??.?X ?.! ' ? e ? ??? ? ?? ? ? ?? JULIE A. KRETZING, Plaintiff V. GEORGE F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6709 CIVIL CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned action on behalf of the Defendant, George F. Kretzing. Respectfully submitted, O'BRIEN, BARIC & SCHERER Date: Mic I Scherer, Esquire I. D. # 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Defendant i 1 CERTIFICATE OF SERVICE hereby certify that on the day of 2008, I, Andrea M. Barrick, of O'Brien, Baric & Scherer, did serve a copy of the Praecipe for Entry of Appearance, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, Pennsylvania 17013 4dAA?nd M. Barrick CJ c ?: , , 125 m CA) JULIE A. KRETZING, Plaintiff, V. GEORGE F. KRETZING, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2007-6709 CIVIL TERM IN DIVORCE MOTION FOR APPOINTMENT OF MASTER JULIE A. KRETZING, Plaintiff„ moves the court to appoint a master with respect to the following claims: a. Equitable distribution of the marital assets; b. Alimony Pendente Lite and Alimony; C. Costs and expenses; and d. Counsel fees. and in support of the motion states: 1. Discovery is complete as the claims(s) for which the appointment of a master is requested. 2. The Plaintiff, Julie A. K.retzing, has appeared in this action by her attorney, Marcus A. McKnight, III, Esquire. 3. The statutory ground for divorce is No-Fault 3301(c). 4. Delete the inapplicable paragraph(s): a. The action is contested. b. An agreement has been reached with respect to the following claims: Divorce C. The action is contested with respect to the following claims: Equitable distribution of the marital assets; Alimony Pendente Lite, Alimony, Costs and expenses; and Counsel fees. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one-half ('/) day. 7. Additional information, if any, relevant to the mot' No Date: April 10, 2008 ttorne for Pla' ORDER APPOINTING MASTER AND NOW , Esquire, is appointed Divorce Master with respect to the following claims: By the Court: J. C? ?? csti ` ? ? -??< ?.? k ? ? ? ^•l'? r "? y ? , ? ? V} ? ? ? ? ?.1 ..?.? APR 15 20OVY JULIE A. KRETZING, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2007-6709 CIVIL TERM GEORGE F. KRETZING, Defendant. IN DIVORCE MOTION FOR APPOINTMENT OF MASTER JULIE A. KRETZING, Plaintiff„ moves the court to appoint a master with respect to the following claims: a. Equitable distribution of the marital assets; b. Alimony Pendente Lite and Alimony; C. Costs and expenses; and d. Counsel fees. and in support of the motion states: 1. Discovery is complete as the claims(s) for which the appointment of a master is requested. 2. The Plaintiff, Julie A. Kretzing, has appeared in this action by her attorney, Marcus A. McKnight, III, Esquire. 3. The statutory ground for divorce is No-Fault 3301(c). 4. Delete the inapplicable paragraph(s): a. The action is contested. b. An agreement has been reached with respect to the following claims: Divorce C. The action is contested with respect to the following claims: Equitable distribution of the marital assets; Alimony Pendente Lite, Alimony, Costs and expenses; and Counsel fees. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one-half ('/2) day. 7. Additional information, if any, relevant to the mots No Date: April 10, 2008 ttorne for Pla' AND NOW Esquire, is appointed Divorce Master with respect to the following claims: ?F_ Aez'-'t i"1 h Lij C _ ?? 1 r9 0 N crz) D o° - V t JULIE A. KRETZING IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. GEORGE F. KRETZING DEFENDANT 2007-6709 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Tuesday, April 15, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, May 06, 2008 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ acqueline M. Verney, Es . . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 FIFO-U i .; E CAF c i ": , ?Y 2008 APR 16 Fa 2: 57 G' , as _ C? ?y r m4y JULIE A. KRETZING, Plaintiff V. GEORGE F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6709 CIVIL TERM CIVIL ACTION - LAW j PRAECIPE TO ATTACH SUBSTITUTE VERIFICATION Please attach the following Substitute Verification to the Custody Complaint filed in this matter on April 9, 2008. Respectfully submitted, { O'BRIEN, BARIC & SCHERER Date: April 22, 2008 &?//j AIA INA ich e A. cherer, Esquire I. D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.d ir/domestic/kre*ing/su bstituteverification-custody. pra JULIE A. KRETZING, Plaintiff V. GEORGE F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6709 CIVIL CIVIL ACTION - LAW VERIFICATION I, George F. Kretzing, verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I hereby ratify the verification previously supplied by my attorney, Michael A. Scherer, Esquire and execute this verification as a substituted verification. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsifications to authorities. Date: 4114 O 1'4-r':ZE Ge . Kretzing CERTIFICATE OF SERVICE I hereby certify that on April , 2008, I, Jennifer S. Lindsay, secretary at O'Brien, Baric & Scherer, serve a copy of the Praecipe To Attach Substitute Verification, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, Pennsylvania 17013 Je fe L dsay JULIE A. KRETZING, Plaintiff V. GEORGE F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6709 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO ATTACH SUBSTITUTE VERIFICATION Please attach the following Substitute Verification to Defendant's Answer To Divorce Complaint and New Matter filed in this matter on April 9, 2008. Respectfully submitted, O'BRIEN, BARIC & SCHERER iAael A. Scherer, Esquire Date: April 22, 2008 1. D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dir/domestic/kre?Zing/substituteverification-divorce.pra JULIE A. KRETZING, Plaintiff V. GEORGE: F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6709 CIVIL CIVIL ACTION - LAW VERIFICATION I, George F. Kretzing, verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I hereby ratify the verification previously supplied by my attorney, Michael A. Scherer, Esquire' and execute this verification as a substituted verification. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsifications to authorities. Date: L1 a m 2? G rg . Kretzing CERTIFICATE OF SERVICE I hereby certify that on April X13 , 2008, I, Jennifer S. Lindsay, secretary at O'Brien, Baric & Scherer, serve a copy of the Praecipe To Attach Substitute Verification, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, Pennsylvania 17013 i e . IL JULIE A. KRETZING, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007 - 6709 CIVIL TERM GEORGE F. KRETZING, CIVIL ACTION - LAW Defendant/Respondent PETITION FOR ECONOMIC RELIEF AND NOW, this 20th day of June 2008, comes the Plaintiff/Petitioner, Julie A. Kretzing, by her attorneys, IRWIN & McKNIGHT, and makes the following Petition for Economic Relief against the Defendant/Respondent, Kjell I. Enge, as follows: 1. The Petitioner is Julie A. Kretzing who is the Plaintiff in a divorce action filed at No. 2007-6709 in Cumberland County, Pennsylvania. Her address is 208 Shughart Avenue, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant, George F. Kretzing, is an adult individual with an address of 1060 Whispering Pines Drive, Wernersville, North Carolina 27284. 3. The petitioner seeks the following relief from the Court: a. Equitable distribution of the marital assets; b. Alimony; C. Costs and expenses; and d. Counsel fees. WHEREFORE, the Petitioner, Julie A. Kretzing, requests the relief set forth above. Respectfully submitted, IRWIN & McKNIGHT By: ECarlisler,PA u .McKnight, III1 es omfret Street 17013 4353 Supreme D. No: 25476 Attorney for e eel loner, Julie A. Kretzing Date: June 20, 2008 2 JULIE A. KRETZING, Plaintiff V. GEORGE F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 6709 CIVIL TERM CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Michael A. Scherer, Esq. 19 West South Street Carlisle, PA 17013 IRWIN & McKNIGHT By: Marcus N. McKnight, I, E 60 West omfret Street Carlisle, 'PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: June 20, 2008 3 'IN Nk" 1 1 VV fa() R T. e fi P ? n 0 r JULIE A. KRETZING, Plaintiff VS. GEORGE F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 6709 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this a3 day of , 2008, there being no issue with respect to grou ds for divorce and no economic claims having been filed, the appointment of the Master is vacated. BY THE COURT, Q I WICA C? Edgar B. Bayley, P.J. cc: ? Marcus A. McKnight, III Attorney for Plaintiff / ? Michael A. Scherer Attorney for Defendant l..?h ??E.S /y1a?L IJ?W t-° C? .": JUL 0 8 2W JULIE A. KRETZING, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-6709 CIVIL ACTION - LAW GEORGE F. KRETZING, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ?day of , 2008, upon consideration of the attached Custody Concil tion eport, it is ordered and directed as follows: I . A Hearing is scheduled in Court Room No. 5 , of the Cumberland County Court House, on the day of 06f&&-r- , 2008, at ,12 (7 o'clock, A. M., at which time testimony will be taken. For purposes of this Hearing, the Father shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be filed at least five days prior to the Hearing date. 2. Pending further Order of Court or agreement of the parties, the provisions of the parties' Separation Agreement and Property Settlement Agreement regarding custody of Matthew T. Kretzing, born June 6, 1993 shall remain in full force and effect. 3. The parties may modify this Order by mutual agreement. In the absence of mutual consent, the terms of this Order shall control. cc: Michael A. Scherer, Esquire, counsel for rather Marcus A. McKnight, III, Esquire, counsel for Mother ,Ge?.ue s BY THE COURT, MNYAWNN3d MNM) " 1`?1 9 0 :01 wv 01 wool AWJ(WiiO8d 3H1 40 3,11.44 JULIE A. KRETZING, Plaintiff V. GEORGE F. KRETZING, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007-6709 CIVIL ACTION - LAW : IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Matthew T. Kretzing June 6, 1993 Mother 2. A Conciliation Conference was held July 3, 2008 with the following individuals in attendance: The Father, George F. Kretzing, with his counsel, Michael A. Scherer, Esquire, and the Mother, Julie A. Kretzing, with her counsel, Marcus A. McKnight, III, Esquire. 3. Father's position on custody is as follows: Father seeks shared legal custody and primary physical custody. Father asserts that the child wishes to relocate to his residence in North Carolina to be with his two older brothers. Father reports that the child says that Mother is depressed. 4. Mother's position on custody is as follows: Mother seeks shared legal and primary physical custody. Mother asserts that the two older children who are in Father's primary physical custody have dropped out of school and are involved with drugs.. 5. The Conciliator recommends an Order in the form as attached scheduling a Hearing and maintaining the status quo. It is expected that the Hearing will require one day. 2-2 Date ac eline M. Verney, Esquire Custody Conciliator JULIE A. KRETZING, Plaintiff V. GEORGE F. KRETZING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND. COUNTY, PENNSYLVANIA NO. 2007 - 670P CIVIL CIVIL ACTION LAW ORDER OF COURT AND NOW, this the day of U'( 6& , 2008, upon relation from counsel for the parties that the parties have reached an,interim agreement, the hearing scheduled in this matter for October 24, 2008 is continued generally. In the event the parties are unable to reach a final agreement, either party may petition the Court to reschedule the hearing. BY THE COUNT, I M. L. Ebert, Jr , J. V chael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 vdarcus A. McKnight, III, Esquire Irwin & McKnight 60 West Pomfret Street Carlisle, Pennsylvania 17013 I q\x n r ?. V?Mi no °7 IIId 6- 130 Boaz