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HomeMy WebLinkAbout07-6751JESSICA J. SILKS, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.,6'? CIVIL TERM IN DIVORCE BRANDEN M. SILKS, Defendant 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. 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 Phone: (717) 249-3166 or (800) 990-9108 JESSICA J. SILKS, Plaintiff V. BRANDON M. SILKS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Jessica J. Silks, an adult individual currently residing at 200 North Mountain Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is Brandon M. Silks, an adult individual currently residing at 383 Grange Hall Road, Millersburg, Dauphin County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 9, 2003, in Dauphin County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. o 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Esquire FPIain'tffif Aorney GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: I I- ? - C -) Q _.» . SICA J. W KY, Plaintiff v w .. .M1 tT"? r ? ? l Q ?' qj? 6 •JD A k \r r lb JESSICA J. SILKS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW BRANDON M. SILKS, NO. 2007-6751 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, thisday of )Wj2j?e"e- , 2007, comes Bradley L. Griffie, Esquire, and states that he mailed a certified and true copy of a Complaint in Divorce to the Defendant, Brandon M. Silks, at his address of 383 Grange Hall Road, Millersburg, Pennsylvania, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on November 15, 2007. rney.for Plaintiff GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Grif e, Esquire A me Plainti i J1 M ' postzil Service RECEIPT M (Domestic Alail On/y: No Provided) cc CO `r' r-? Postage $ O Certified Fee ii O ,0 Retum Receipt Fee (Endorsement Required) i CO Ee?mentRegi red) R ?? ( e a Fen t l P f1J ag os Tota O O r- ent To 177, -- ....... 2, grNdeNurer 7002 0860 0001 5848 8133 r - ia9ses-a¢-a?tsw - Fslum Pei 1 ?k ? 2Q?1 i ' B ly (i4rh?9d Mirt?sl C. Diivte d DewerY ALT- D. Is derwN m=17 yo K. Yli$, OnW doomy addraas adow El 3. ftinks'N" PO*O *w M"00106 :13 ft*mml /-704)/ item 4 It AGOWW DWWY Is ¦ Prk t Yq w- nayre WWI addrew on the ' sd eW w6 can yOkL #w bwk Of 10 R ?? or trios fr'yif GPM* ' 1 mad to: GPM* a :20% A 01. +- icy JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6751 BRANDEN M. SILKS, : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of John J. Connelly, Jr., Esquire, on behalf of the Defendant, Branden M. Silks, in the above-captioned action. Date: ;? 170 0,5 By: ?X? ohn onn y, Jr., Esqu' e e 15615 Post Office Box 650 Hershey, PA 17033 (717) 533-3280 r-° s :'? "Y"i :?' ^y-t "" ^-["? ? s ("i } -^_ _ s w ._? a ?i? „ys 4 John J. Connelly. Jr., Esquire Attorney J.D. No. 15615 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Defendant JESSICA J. SILKS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. BRANDEN M. SILKS, Defendant NO. 07-6751 CIVIL ACTION - LAW IN DIVORCE PETITION RAISING ECONOMIC CLAIMS AND NOW, comes the Defendant, Branden M. Silks, by and through his attorney, John J. Connelly, Jr., Esquire, and James, Smith, Dietterick & Connelly, LLP, and files the following Petition Raising Additional Claims: COUNTI CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE Plaintiff and Defendant are the owners of various real and personal property, motor vehicles, bank accounts and insurance policies acquired during their marriage which are subject to equitable distribution by this Court. WHEREFORE, the Plaintiff requests the Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; b. equitably distributing all property owned by the parties hereto; and C. for such further relief as the Court may determine equitable and just. Dated: R < v Z> By: Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP J J. onn lly, Jr. tto y I. #15615 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant JESSICA J. SILKS, Plaintiff v. BRANDEN M. SILKS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6751 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for the Defendant, Branden M. Silks, hereby certify that I have served a copy of the foregoing Petition Raising Economic Issues on the following on the date and in the manner indicated below: VIA U.S. MAIL, FIRST CLASS, PRE-PAID Bradley L. Griff e, Esquire Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated:01 A o By: lly, J. Jo J. Co 7#156r5 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant a t 0 CIO r_l 00 JESSICA J. SILKS, Plaintiff V. BRANDEN M. SILKS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2007-6751 CIVIL TERM IN DIVORCE PETITION FOR ECONOMIC RELIEF IN THE FORM OF ALIMONY, ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES AND NOW, comes Petitioner, Jessica J. Silks, by and through her counsel, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1. Petitioner has filed a Complaint in Divorce to the above docketed number on November 7, 2007. 2. The Complaint in Divorce solely raises the issue of divorce, requesting a divorce be entered in this matter pursuant to Section 3301(c) of the Divorce Code of 1980 as amended. 3. Petitioner incorporates herein all of the averments and statements set forth in said Complaint in Divorce, which is attached hereto and incorporated herein by reference as Exhibit "A". COUNTI ALIMONY, ALIMONY PENDENTE LITE, AND COUNSEL FEES 4. Paragraphs 1 through 3 are incorporated herein by reference as if set forth in their full text. 5. Plaintiff is unable to provide for, or afford her counsel fees, expenses and costs during the pendency of this divorce action, and through its resolution. 6. Plaintiff is without sufficient property and otherwise unable to financially support herself through appropriate employment. 7. Defendant is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses, and costs, as well as alimony, and alimony pendente lite for the Plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring Defendant to pay for Plaintiffs counsel fees, expenses, and costs as well as providing for payment of an appropriate alimony and alimony pendente lite to Plaintiff. Respectfully submitted, e, Esquire Ofo.?Petitioner 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: 3.3 " 615?iCA J S I JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW BRANDEN M. SILKS, : NO. O 7 - !e 7S1 CIVIL TERM n F- =J ° Defendant IN DIVORCE Q NOTICE TO DEFEND AND CLAIM RIGHTS G3 ?' 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. 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 Phone: (717) 249-j1 @Y QW6) 90-9108 I JESSICA J. SILKS, Plaintiff V. BRANDON M. SILKS, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. D 7-(? 7-57 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Jessica J. Silks, an adult individual currently residing at 200 North Mountain Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is Brandon M. Silks, an adult individual currently residing at 383 Grange Hall Road, Millersburg, Dauphin County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 9, 2003, in Dauphin County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, e, Esquire 4jorney r Plaintiff f GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsifications to authorities. DATE:-11-4,6 SICA J. O&V, Plaintiff I G CIO C) C= 0 rn Cc -77 DR#: JESSICA J. SILKS, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW BRANDEN M. SILKS, NO. 2007-6751 CIVIL TERM Defendant/Respondent : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE, INTERIM COUNSEL FEES AND EXPENSES AND NOW comes Petitioner, Jessica J. Silks, by and through her counsel of record, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1. Your Petitioner is the above named Plaintiff, Jessica J. Silks, an adult individual currently residing at 200 North Mountain Road, Newville, Cumberland County, Pennsylvania. 2. Your Respondent is the above named Defendant, Branden M. Silks, an adult individual currently residing at 383 Grange Hall Road, Millersburg, Pennsylvania. 3. Petitioner's date of birth is January 30, 1985, and her Social Security number is 205- 70-9286. 4. Respondent's date of birth is August 28, 1981, and his Social Security number is 169- 70-5621. 5. The divorce action filed to the above docketed number in the Court of Common Pleas of Cumberland County requests a divorce based upon Section 3301(c) of the Divorce Code of 1980 as amended. 6. Petitioner has employed counsel and will incur certain costs and expenses in pursuit of the aforementioned divorce action, but is without sufficient assets or income to support herself, pay for attorney's fees, or pay for the costs and expenses associated with this action. 7. Respondent has sufficient income and earning capacity, as well as assets, to support the Petitioner or to assist in supporting Petitioner, and to pay alimony pendente lite to Petitioner, as well as assist in paying her counsel fees, costs and expenses. 8. Petitioner and Respondent no longer reside together. WHEREFORE, Petitioner request you Honorable Court to enter an Order of Alimony Pendente Lite, Interim Counsel Fees, Costs and Expenses in this matter. Respectfully submitted, Gr' fie, Esquire t rney for laintiff/Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: <3 E SIC I , Plaintiff/Petitioner n r.., cia .? -n ril o m - o m CY% -< JESSICA J. SILKS, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 07-6751 CIVIL TERM BRANDEN M. SILKS, IN DIVORCE Defendant/Respondent PACSES CASE NO: 444109871 ORDER OF COURT AND NOW, this 10th day of March, 2008, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R. J. Shadday on April 1, 2008 at 1:30 P.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you. If you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Bradley L. Griffie, Esq. John J. Connelly, Jr., Esq. Date of Order: March 10, 2008 4. J. S ay, o erence O icer r? YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 cc361 (717) 249-3166 t7 C N ?, O co njrr- - -5 r-5 rT' It nk JESSICA J. SILKS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION BRANDEN M. SILKS, PACSES NO. 256109624 Defendant DOCKET NO. 970 SUPPORT 2007 JESSICA J. SILKS, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION BRANDEN M. SILKS, : PACSES NO. 444109871 Defendant/Respondent : DOCKET NO. 07-6751 CIVIL TERM ORDER OF COURT AND NOW, this 19th day of March, 2008, this matter having been scheduled for a hearing de novo before the Support Master on the Plaintiffs Complaint for spousal support and child support, and the parties having reached an agreement on all outstanding issues, upon recommendation of the Master, it is ordered and decreed as follows: A. In the case docketed to 970 Support 2007 that portion of the interim order dated January 8, 2008 obligating the Defendant to pay $163.00 per month as spousal support is vacated; in all other respects said order is affirmed as a final order. B. In the case docketed to 07-6751 Civil the Defendant shall pay to the Pennsylvania State Collection and Disbursement Unit as alimony pendente lite the sum of $163.00 per month effective November 19, 2007. C. All payments heretofore made by the Defendant as spousal support to PACSES Case No. 256109624 shall be applied as alimony pendente lite to PACSES Case No. 444109871. e u „- G Edgar B. Bayley, J. id??` did 70 'If ?d? Cc: Jessica J. Silks Branden M. Silks Bradley L. Griffie, Esquire For the Plaintiff John J. Connelly, Jr., Esquire For the Defendant DRO 16 IN T14E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - DOMESTIC RELATIONS SECTION PACSES CASE # 444109871 DOCKET# 07-6751 CIVIL TERM JESSICA J. SILKS, V. BRANDEN M. SILKS, Defendant Plaintiff IN SUPPORT STIPULATION AND NOW, the day and year hereinafter set forth, the parties hereto stipulate and agree as follows: 1. There is presently in existence a Support Order through the Cumberland County Domestic Relations Office docketed to Docket Number 00970 AS 2007 and PACSES CASE Number 256109624. 2. The Order entered in that action dated January 8, 2008, provides for the payment of support in the amount of $163.00 per month for spousal support for the Plaintiff named herein, and $248.00 per month in child support to the Plaitniff for the parties' child, Hunter James Silks, born February 17, 2007. 3. Defendant filed a request for a de novo hearing on the support Order entered on January 8, 2008. 4. In full and final resolution of all issues to be raised by the Defendant in this de novo hearing, the parties hereby request that the Court of Common Pleas of Cumberland, Pennsylvania, Domestic Relations Section, modify the Order of January 8, 2008 solely by providing that the payments made from the Defendant to Plaintiff for her support be renamed "alimony pendente lite" rather than "spousal support". 5. This sole modification shall be implemented upon receipt of this Stipulation by the Cumberland County Domestic Relations Office. 6. It is not the intension of either party to have any other terms of the Order of January 8, 2008 modified. WHEREFORE, the parties hereto have set forth their hands and seals the day and year hereinafter written intending to be legally bound thereby. 3-3°08' ` s WCiffie, Esquire Date JESSIC J IL 4 0 . Co elly, squi Date BRANDEN SILKS w ?{ Z. C7 , W3.. 3 JESSICA J. SILKS, IN THE COURT OF COMMON PT F,AS OF Plaintiff CUMBERLAND COUNTY, PFNlvSYLVANIA V. CIVIL ACTION - LAW BRANDFN M. SILKS, NO. 2007-6751 CIVIL TF,RM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on Novembet 7, 2007, and service xw inado oii Novmioer 1.5. "007 ,,- r t i? rc„' delivery, certified mail. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I i_1NDERSTAND "THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. JS,SICA J. SI , aintiff L ?i? -Ti , N) 1 C, cr, JESSICA J. SILKS, Plaintiff V. BRANDEN M. SILKS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-6751 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODF I . 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 decree 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 P.S. §4904 RELATING TO U SWOIRUN' FALSIFICATiOTv " k:) UTIIG?i•ilcs (??C DATE: 6 -- SICA Plaintiff C c ^. O JESSICA J. SILKS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW BRANDEN M. SILKS, : NO. 2007-6751 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on November 7, 2007, and service was made on November 15, 2007 by restricted delivery, certified mail. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: Ad, BRANDEN M SILKS, efendant cr) (^?" Y `w `.` I JESSICA J. SILKS, Plaintiff V. BRANDEN M. SILKS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007-6751 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER.43301(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 decree 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 THE FOREGOING 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: 4 zslat B DEN M. KS, efendant C? "'? C ' ` C`S _ ?,. ? ?a r?_ 4 ?ro; c r c: _ , r? _? ??? r;-,_ , r-z ?.+ , `? _ .x?E: 3i o-"t . .?' , ,;^3 -?. - °? JESSICA J. SILKS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL, ACTION -- LAW BRANDEN M. SILKS, NO. 2007-6751 CIVIL TERM Defendant IN DIVORCE. STIPULATION FOR BIFURCATION AND NOW come the parties, Jessica L. Silks, Plaintiff, and Brandon M. Silks, Defendant, by and through their counsel of record, hereinafter named, to stipulate and agree as follows: 1 2. 3 4 5 A divorce action was initiated in this matter by Jessica J. Silks (hereinafter Plaintift) on November 7, 2007. Service of the Complaint was made upon Brandon M. Silks (hereafter Defendant) on November 15, 2007 by certified mail, restricted delivery. Subsequent to the filing of the divorce action, the parties have raised collatera; economic issues in the proceedings which are of record. The parties wish to separate the divorce proceeding from the claims for economic relief as set forth in this action. The parties wish to finalize their divorce pursuant to section 3301 (c) of the Domestic Relations Code, as amended, while the Court retains jurisdiction over the economic issues raised in this matter. 6. The parties specifically request that the Court enter an Order bifurcating the divorce proceedings from the collateral economic issues raised in the proceeding, such that the parties can secure a Decree in Divorce while maintaining their economic claims as raised. WHEREFORE, the parties hereto have set forth their hand and seal the day and year hereinafter written intending to be legally bound and to legally bind thereas executors and assigns. WITNESSETH: Br riffi IL Date VOr., E u re Da e Branden A Silks COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF CUMBERLAND On this, the /6 A day of , 2008, before me the undersigned officer, personally appeared JESSICA J. SILKS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing instrument and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. 5 ---` s-c- ---- - Notary Public COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF 6kf" On this, the A3 ?--4 day of 90--K- J.r VAN" M WjW , 2008, before me the undersigned officer, personally appeared BRANDF,N M. SILKS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the fore.voinu instrument and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. < G?IJ?..1C.?t.` Not y Public H OF PENNSY VA MA l ary Ptdc COMMRR;j in Cotarty s Nov. 9, 2009 My Member, Pennsylvania Association of Notaries TIR444 _.0000 + vqw_ JUL 012008 JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW BRANDEN M. SILKS, NO. 2007-6751 CIVIL TERM Defendant IN DIVORCE ORDER OF COURT AND NOW this 3?__"y of , 2008, upon presentation and consideration of the within Stipulation, IT IS HEREBtOORD E RE AND DIRECTED that the parties' divorce proceedings are bifurcated such that the parties may finalize their divorce pursuant to Section 3301(c) of the Domestic Relations Code, as amended, with the Court retaining jurisdiction over all other issues raised in this matter. The Alimony Pendente Lite (APL) Order docketed to PACSES Case Number 444109871 shall continue pending further Order of Court or agreement of the parties otherwise. Cc: "Bradley L. Griffie, Esquire Attorney for Plaintiff `/John J. Connelly, Jr., Esquire Attorney for Defendant 7`3?os s Ck. c? m JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. BRANDEN M. SILKS, Defendant CIVIL ACTION - LAW NO. 07-6751 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 §3301(c) 3301(d)(1) of the Divefee Gede. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on November 15, 2007. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: June 26, 2008 by Defendant: June 23, 2008 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: Plaintiff's claim for alimony, alimony pendente lite, counsel fees, expenses and costs; Defendant's claim for equitable distribution. 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 of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: June 26, 2008 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: June 26, 2008 nffie, Esquire F ASSOCIATES Attorney for Plaintiff c? rr; cz ` ti • ? C3 "'? _ _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JESSICA J. SILKS Plaintiff VERSUS RRANDEN M. SILKS, Defendant NO. 07-6751 Civil Term DECREE IN DIVORCE AND NOW, / ? IT IS ORDERED AND top- DECREED THAT Jessica J. Silks , PLAINTIFF, AND BRANDEN M. SILKS DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECD D IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; MK-e The court retains jurisdiction over all collateral issues raised in prior pleadings. The Alimony P&idente Lite Order, docketed to 07-6751 and PACSES No. 444109871, shall ren ai.n in effect er Order of Court or agreempgt of the parties. i BY THE ATTEST: S' J. PROTHONOTARY k John J. Connelly, Jr., Esquire Attorney I.D. No. 15615 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Defendant/Petitioner JESSICA J. SILKS, P l ainti ff/Respondent v. BRANDEN M. SILKS, Defendant/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6751 CIVIL ACTION - LAW IN DIVORCE PETITION TO JOIN ADDITIONAL PARTIES AND NOW, comes the above-named Defendant, Branden M. Silks, in the above-captioned divorce action, by and through his counsel, John J. Connelly, Jr., Esquire, and the law firm of James, Smith, Dietterick & Connelly, LLP and respectfully requests this Honorable Court to add additional parties, Richard J. Hill and Patricia A. Hill, in the above-referenced matter and in support thereof avers the following: 1. The Petitioner is Branden M. Silks, Defendant in the above-captioned action, whose current address is 383 Grange Hall Road, Millersburg, Dauphin County, Pennsylvania 17061. 2. The Respondent is Jessica J. Silks, Plaintiff in the above-captioned action, who currently resides at 200 North Mountain Road, Newville, Cumberland County, Pennsylvania 17241 (hereinafter "marital residence"). Bradley L. Griffie, Esquire represents Respondent in the above-captioned action. 3. Richard J. Hill and Patricia A. Hill currently reside at 198 North Mountain Road, Newville, Cumberland County, Pennsylvania 17241 and are indispensable parties to this action. 4. Richard J. Hill and Patricia A. Hill are Plaintiff's parents. 5. The parties were married on August 9, 2003. 6. On November 7, 2007, Plaintiff filed her Divorce Complaint. 7. On February 27, 2008, Defendant filed his Petition raising economic claims including a claim for equitable distribution of marital property. 8. From 2003 through 2007, Defendant constructed the parties' marital residence, garage and barn on land which is owned by Plaintiff's parents, Richard J. Hill and Patricia A. Hill. 9. In addition to Defendant's own financial contributions toward the cost of construction, the parties took out loans in 2003 and 2006 relative to the construction of the marital residence, garage and barn. 10. The parties' loan in 2003 for the construction and improvements to their marital residence was secured by Defendant's parents' residence, whose address is 383 Grange Hall Road, Millersburg, PA. 11. During the parties' marriage, the parties maintained and paid for home insurance regarding their marital residence, garage and barn. 12. During the parties' marriage, the parties contributed towards the real estate taxes regarding the marital residence, garage and barn. 13. Although the property on which the marital residence is situated is titled in the names of Richard J. Hill and Patricia A. Hill, the parties have a substantial equitable interest in said property. This equitable interest is marital property. 2 14. Defendant believes and therefore avers that Plaintiffs parents are indispensable parties to the above-referenced divorce action since the parties' marital residence and other structures located at 200 North Mountain Road, Newville, Cumberland County, Pennsylvania were constructed on Plaintiff s parents' land. 15. Richard J. Hill and Patricia A. Hill deny that Defendant has any equitable interest in the marital residence or other structures located at 200 North Mountain Road, Newville, Cumberland County, Pennsylvania. 16. The authority of this Court to join Richard J. Hill and Patricia A. Hill as additional parties is under Pa.R.C.P. § 1920.34 and VanBuskirk v. VanBuskirk, 527 Pa. 218, 590 A.2d 4 (1991). 17. It is essential to join Richard J. Hill and Patricia A. Hill in this action because the equitable distribution of marital property is subject to the jurisdiction of the Court in the above- captioned action. 18. Pursuant to Local Rule 208.3(a), the Honorable Edgar B. Bayley entered an Order dated July 3, 2008 bifurcating the parties' divorce matter based upon the Stipulation of the parties filed with this Court on June 30, 2008. Additionally, the parties appeared before the Honorable Edward E. Guido for a custody hearing on January 25, 2008 at which time the parties entered into a Stipulation regarding custody, whose docket number is 2007-6688. WHEREFORE, Defendant respectfully requests that this Court enter an Order joining Richard J. Hill and Patricia A. Hill as indispensable parties to this action as co-Defendants and to amend the caption to reflect same. 3 Dated: I -o q- c) ?K By: Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Attorneys for Defendant/Petitioner Hershey, PA 17033-0650 (717) 533-3280 VERIFICATION I, Branden M. Silks, verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date: / 2Gb? Branden M. Silks r JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6751 BRANDEN M. SILKS, : CIVIL ACTION - LAW Defendant/Petitioner : IN DIVORCE CERTIFICATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for the Defendant, Branden M. Silks, hereby certify that I have served a copy of the foregoing Petition to Join Additional Parties on the following on the date and in the manner indicated below: VIA U.S. MAIL. FIRST CLASS. PRE-PAID Bradley L. Griffie, Esquire Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 Richard J. Hill & Patricia A. Hill, pro se 198 North Mountain Road Newville, PA 17241 JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: 7, a . ?g By: (__ K4 o J. Conn lly, Jr. rn I.D 15615 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant ? ? ??., °- ?-.._ ?-? n `a -- ?...._ ? . r-; tt \I V ? i ? .r.?.:n 1. '_ ? • t t r d ; L JUL282UUtlV4 JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6751 BRANDEN M. SILKS, : CIVIL ACTION - LAW Defendant : IN DIVORCE ORDER AND NOW, this day of July, 2008, upon consideration of the foregoing Petition, it is hereby ordered that: 1. A Rule is issued upon Respondent, Jessica J. Silks, and upon Richard J. Hill and Patricia A. Hill, to show cause why Richard J. Hill and Patricia A. Hill should not be joined as indispensable parties in the above-captioned action; 2. Respondent, Jessica J. Silks, and Richard J. Hill and Patricia A. Hill, shall file an Answer to Defendant's Petition to Join Additional Parties within _!?days of the date of this Order; a 3. The Petition shall be decided under Pa. R.C.P. No. 206.7; 4. Argument shall be held on the ? day of rb?? 2008, at e a.m./p.m., in Courtroom No, 1 _ . Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania to determine whether Richard J. Hill and Patricia A. Hill will be joined as parties to the above-captioned matterjamik 5. Notice of the entry of this Order shall be provided to all parties and to Richard J. Hill and Patricia A. Hill by the Petitioner. By the Co , J. Distribution: VYohn J. Connelly, Jr., Esquire, P.O. Box 650, Hershey, PA 17033 VB'radley L. Griffie, Esquire, 200 North Hanover Street, Carlisle, PA 17013 ,,-Richard J. Hill and Patricia A. Hill, 198 North Mountain Road, Newville, PA 17241, pro se V OPAA? D `3_ r- L`'? CD tsJ C LL- C, C a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - DOMESTIC RELATIONS SECTION JESSICA J. SILKS, Plaintiff VS. BRANDEN M. SILKS, Defendant PACSES CASE # 444109871 DOCKET # 07-6751 CIVIL TERM IN SUPPORT MOTION TO WITHDRAW AS COUNSEL AND NOW, comes Petitioner, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1. Petitioner is Bradley L. Griffie, Esquire, counsel of record for the above named Plaintiff, Jessica J. Silks, with an office address of 200 North Hanover Street, Carlisle, Cumberland County, Pennsylvania. 2. Respondent is Jessica J. Silks, an adult individual currently residing at 200 North Mountain Road, Newville, Cumberland County, Pennsylvania. 3. Respondent has determined that she wishes to proceed in the above captioned matter, pro se, from this point forward and has requested that Petitioner withdraw as counsel in this matter. 4. Respondent has indicated that she does not have the financial means to pay Petitioner for any additional legal services for legal representation in the above captioned matter. 5. At the present time, the parties have secured a bifurcated divorce and have been divorced from the bonds of matrimony. 6. There are no matters pending at this time in this matter. 7. Petitioner has given Respondent notice that the within Petition will be filed and Respondent concurs in this request. WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon Respondent to show cause, if any she has, as to why Petitioner should be permitted to withdraw as counsel in the above captioned matter. Respectfully submitted, . G ' ie, Esquire A orney r Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATES?? d ri e, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - DOMESTIC RELATIONS SECTION JESSICA J. SILKS, PACSES CASE # 444109871 Plaintiff DOCKET # 07-6751 CIVIL TERM Vs. BRANDEN M. SILKS, Defendant IN SUPPORT CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire hereby certify that I did, the 51h day of August, 2008, cause a copy of the within Motion to Withdraw as Counsel to be served upon the Respondent, Jessica J. Silks, by serving her by first class mail, postage prepaid, at the following address and upon the Defendant, Branden M. Silks, by serving his attorney of record, at the following address: Jessica J. Silks 200 North Mountain Road Newville, PA 17241 John J. Connelly, Jr., Esquire PO Box 650 Hershey, PA 17033 DATE: - a S, L,. 9fiffie, Esquire y Or Petitioner m ;:. ?zj tiw M JESSICA J. SILKS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW BRANDEN M. SILKS, NO. 07-6751 CIVIL TERM Defendant IN DIVORCE MOTION TO WITHDRAW AS COUNSEL AND NOW, comes Petitioner, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1. Petitioner is Bradley L. Griffie, Esquire, counsel of record for the above named Plaintiff, Jessica J. Silks, with an office address of 200 North Hanover Street, Carlisle, Cumberland County, Pennsylvania. 2. Respondent is Jessica J. Silks, an adult individual currently residing at 200 North Mountain Road, Newville, Cumberland County, Pennsylvania. 3. Respondent has determined that she wishes to proceed in the above captioned matter, pro se, from this point forward and has requested that Petitioner withdraw as counsel in this matter. 4. Respondent has indicated that she does not have the financial means to pay Petitioner for any additional legal services for legal representation in the above captioned matter. 5. At the present time, the parties have secured a bifurcated divorce and have been divorced from the bonds of matrimony. 6. The Defendant in the divorce case, Branden M. Silks, through his counsel, John J. Connelly, Esquire, has initiated the filing of a Petition to add additional parties to the collateral issues pending in the divorce case. 7. Respondent has advised Petitioner that she believes she can handle these matters without legal counsel and, further, is not going to be able to pay legal counsel to represent her in these proceedings. 8. The principle focus of the pending proceedings are to include Respondent's parents as parties to the instant action, which will necessitate Respondents' parents securing legal counsel, who will represent them in this matter. 9. Petitioner previously advised Respondent that Petitioner was filing the instant Petition, at Respondent's request, and Respondent concurs in the request herein. WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon Respondent to show cause, if any she has, as to why Petitioner should be permitted to withdraw as counsel in the above captioned matter. Respectfully submitted, r riffie, Esquire ttorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 .. I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. DATE: L. Gr' ie, Esquire JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW BRANDEN M. SILKS, NO. 07-6751 CIVIL TERM Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire hereby certify that I did, the 51h day of August, 2008, cause a copy of the within Motion to Withdraw as Counsel to be served upon the Respondent, Jessica J. Silks, by serving her by first class mail, postage prepaid, at the following address and upon the Defendant, Branden M. Silks, by serving his attorney of record, at the following address: Jessica J. Silks 200 North Mountain Road Newville, PA 17241 John J. Connelly, Jr., Esquire PO Box 650 Hershey, PA 17033 DATE: ? 6 ?--Griffie, Esquire for Petitioner =? 21 c 9 w 4& JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW BRANDEN M. SILKS, NO. 07-6751 CIVIL TERM Defendant IN DIVORCE AMENDED MOTION TO WITHDRAW AS COUNSEL AND NOW, comes Petitioner, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1. Petitioner is Bradley L. Griffie, Esquire, counsel of record for the above named Plaintiff, Jessica J. Silks, with an office address of 200 North Hanover Street, Carlisle, Cumberland County, Pennsylvania. 2. Respondent is Jessica J. Silks, an adult individual currently residing at 200 North Mountain Road, Newville, Cumberland County, Pennsylvania. 3. Respondent has determined that she wishes to proceed in the above captioned matter, pro se, from this point forward and has requested that Petitioner withdraw as counsel in this matter. 4. Respondent has indicated that she does not have the financial means to pay Petitioner for any additional legal services for legal representation in the above captioned matter. 5. At the present time, the parties have secured a bifurcated divorce and have been divorced from the bonds of matrimony. 6. The Defendant in the divorce case, Branden M. Silks, through his counsel, John J. Connelly, Esquire, has initiated the filing of a Petition to add additional parties to the collateral issues pending in the divorce case. 7. Respondent has advised Petitioner that she believes she can handle these matters without legal counsel and, further, is not going to be able to pay legal counsel to represent her in these proceedings. 8. The principle focus of the pending proceedings are to include Respondent's parents as parties to the instant action, which will necessitate Respondents' parents securing legal counsel, who will represent them in this matter. 9. Petitioner previously advised Respondent that Petitioner was filing the instant Petition, at Respondent's request, and Respondent concurs in the request herein. 10. Notice has been given to counsel for the Defendant in this matter, John J. Connelly, Jr., Esquire, who does not oppose this request. 11. There has been no Judge involved in the above referenced divorce proceeding, however, Judge Edward E. Guido has ruled in matters regarding custody between the parties. WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon Respondent to show cause, if any she has, as to why Petitioner should be permitted to withdraw as counsel in the above captioned matter. Respectfully submitted, Grifl ie, Esquire 4tommey for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: 8'f iA , 3- 40Grif0e, Esquire .i JESSICA J. SILKS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW BRANDEN M. SILKS, NO. 07-6751 CIVIL TERM Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire hereby certify that I did, the 15`h day of August, 2008, cause a copy of the within Motion to Withdraw as Counsel to be served upon the Respondent, Jessica J. Silks, by serving her by first class mail, postage prepaid, at the following address and upon the Defendant, Branden M. Silks, by serving his attorney of record, at the following address: Jessica J. Silks 200 North Mountain Road Newville, PA 17241 John J. Connelly, Jr., Esquire PO Box 650 Hershey, PA 17033 DATE: / ? J ?? ?ti a?. ? ? ?? w '_?t` . J ' ~ CTS --'G JESSICA J. SILKS, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BRANDEN M. SILKS, : DEFENDANT 07-6751 CIVIL TERM ORDER OF COURT AND NOW, this ,-? day of September, 2008, the motion of Bradley L. Griffie, Esquire, to withdraw as counsel for Jessica J. Silks, IS GRANTED. ,,,Jer!§sica J. Silks, Pro se 200 North Mountain Road Newville, PA 17241 ,,d6^hn J. Connelly, Jr., Esquire For Defendant .,A rradley L. Griffie, Esquire E. Robert Elicker, Divorce Master J Edgar 'V/ -1 ,J :sal L i' a --j CX7 JESSICA J. SILKS, Plaintiff VS. BRANDEN M. SILKS, Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : NO. 07-6751 CIVIL TERM : IN DIVORCE : Judge Edgar B. Bayley PRAECIPE Pursuant to the Court's Order of September 2°d, 2008, please withdraw my appearance on behalf of the Plaintiff, Jessica J. Silks, in the above captioned matter. DATE: 61110(o Y Mr' ie, Esquire ASSOCIATES h Hanover Street t Carlisle, PA 17013 (717) 243-5551 1. -.'` ?, ? ? c? :.-? `..? JESSICA J. SILKS, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BRANDEN M. SILKS, DEFENDANT 07-6751 CIVIL TERM r ORDER OF COURT AND NOW, this `L day of October, 2008, following receipt of briefs and consideration of oral argument, IT IS ORDERED that the petition of Branden M. Silks to join plaintiffs' parents, Richard J. Hill and Patricia A. Hill as additional defendants, IS GRANTED. /Jessica J. Silks, Pro se 200 North Mountain Road Newville, PA 17241 ,/Richard J. Hill Patricia A. Hill 198 North Mountain Road Newville, PA 17241 / ? Christine Taylor Brann, Esquire For Defendant sal COP i ?ES mat /OCL 1 )m C's ?? •-ct ??r?' ?4 t t... ? ..§ :?. «` :::c.` • c ?.??? ?: G JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6751 BRANDEN M. SILKS, : CIVIL ACTION - LAW Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Branden M. Silks, Defendant, moves the court to appoint a Master with respect to the following claims: () Divorce () Annulment () Alimony () Alimony Pendente Lite ( x ) Distribution of Property () Support () Counsel Fees () Costs and Expenses and in support of the motion states: (1) Discovery is substantially complete as to the claims for which the appointment of a master is requested, except for updated financial information. Any appraisals or updates which remain outstanding will be finalized in advance of a Master's Hearing. (2) The Plaintiff initially appeared in this matter personally and through her counsel, Bradley L. Griffie, Esquire, but is currently proceeding pro se. Plaintiff has appeared in the parties' separate custody matter at Docket No. 07-6688 personally and through her counsel, Nathan C. Wolf, Esquire. (3) The statutory ground(s) for divorce are: Decree in Divorce dated July 15, 2008 entered by the Honorable Edgar B. Bayley which preserves the economic issues raised in the parties' pleadings. (4) Check the applicable paragraph(s) () The action is not contested. () An agreement has been reached with respect to the following claims: (x) The action is contested with respect to the following claims: Equitable distribution (5) The action does involve a complex issue of law or fact. According to this Court's Order dated October 7, 2008, Richard J. Hill and Patricia A. Hill, the parents of Plaintiff, Jessica silks, were joined as additional defendants as the marital residence was constructed upon the land owned by them. (6) The hearing is expected to take one day. (7) Additional information, if any, relevant to the Motion: n/a JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: 9 By: John J. Connelly, Jr. Attorney 1. D. #15615 Christine Taylor Brann Attorney I.D. #82204 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6751 BRANDEN M. SILKS, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Christine Taylor Brann, Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for the Defendant, Branden M. Silks, hereby certify that I have served a copy of the foregoing Motion for Appointment of Master on the following on the date and in the manner indicated below: VIA U.S. MAIL, FIRST CLASS, PRE-PAID Jessica J. Silks, pro se 200 North Mountain Road Newville, PA 17241 Richard J. Hill & Patricia A. Hill, pro se 198 North Mountain Road Newville, PA 17241 JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: By: Christine Taylor Brann Attorney I.D. #82204 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant Fl FF- CE OF THE P, MO TARP 2009 SEP -8 PM 1: 54 V4{fi?L?s{4+?..r:::;t Yt (L /?{r £.;gw1}?l.)! V? PEA I . JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6751 BRANDEN M. SILKS, : CIVIL ACTION - LAW Defendant : IN DIVORCE INCOME STATEMENT OF BRANDEN M. SILKS I, Branden M. Silks, verify that the statements made in this Income and Expense Statement 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: ?2 OP ?? Branden M. Silks, efendant INCOME Employer: Address: Type of Work: Payroll Number: Self-employed 47 Dogwood Lane Cleona, PA 17042 Carpenter Contractor's license #011886 Pay Period (weekly, biweekly, etc.): Gross Pay per Pay Period: Itemized Payroll Deductions: Federal Withholding FICA Local Wage Tax State Income Tax Mandatory Retirement Union Dues Health Insurance Other (specify) See supplemental Income Statement and 2008 Federal Income Tax Return attached hereto. Net Pay per Pay Period: $ OTHER INCOME: Interest Dividends Pension Distributions Annuity Social Security Rents Royalties Unemployment Comp. Workers Comp. Employer Fringe Benefits Other None WEEK MONTH (Fill in appropriate column) TOTAL $ $ TOTAL INCOME $ $ YEAR $ PROPERTY OWNED Checking accounts Savings accounts Credit Union Stocks/bonds Real estate Other INSURANCE Hospital Blue Cross Other Medical Blue Shield Other Health/Accident Disability Income Dental Other See Inventory Ownership Description Value H W J Total $ Coverage Company Policy No. H W J Highmark PPO Blue Shield #1020019380010 Client to specify SUPPLEMENTAL INCOME STATEMENT (a) This form is to be filled out by a person (check one): X (1) who operates a business or practices a profession, or (2) who is a member of a partnership or joint venture, or (3) who is a shareholder in and is salaried by a closed corporation or similar entity. (b) Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, professional, corporation or similar entity: (1) the most recent Federal Income Tax Return, and (2) the most recent Profit and Loss Statement. (c) Name of business Branden M. Silks Address and 47 Dogwood Lane Cleona, PA 17042 Telephone Number: (717) 440-3615 (d) Nature of business (check one): (1) partnership (2) joint venture X (3) profession (4) closed corporation (5) other (e) Name of accountant, controller or other person in charge of financial records: Keith Rainey, Office Manager, H&R Block, 914 N. River Road, Halifax, PA 17032 (f) Annual income from business: Average $20,000 (1) How often is income received? By jobs completed (2) Gross income per pay period: By jobs completed (3) Net income per pay period: By jobs completed (4) Specified deductions, if any: See 2008 Federal Tax Return JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6751 BRANDEN M. SILKS, : CIVIL ACTION - LAW Defendant : IN DIVORCE EXPENSE STATEMENT OF BRANDEN M. SILKS I, Branden M. Silks, verify that the statements made in this Expense Statement 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: 22 d Q 2 Branen M. Silks, Defendant Monthly Monthly Monthly Total Children Parent EXPENSES Home Mortgage $303.92 Maintenance $100.00 Lawn Care 2nd Mortgage (/2 cost of $280.00 current residence) UTILITIES Electric ('/2 cost of current residence) $75.00 Gas on Telephone $15.00 Cell Phone $50.00 Water $12.00 Sewer Cable TV $28.00 Internet $28.00 Trash/Recycling $27.00 TAXES Real Estate (included in mortgage payments) Personal Property Monthly Total INSURANCE Homeowners Automobile Life Accident/Disability Excess Coverage/Liability Long-Term Care AUTOMOBILE Lease Payments Fuel Repairs Memberships MEDICAL Medical Insurance Doctor Dentist Hospital Medication Counseling/Therapy (Interworks) Orthodontist Special Needs (glasses, etc.) $245.00 $41.00 $25.00 $345.83 $480.00 $50.00 $151.45 $40.00 $5.00 $15.00 Monthly Monthly Children Parent EDUCATION Tuition Tutoring Lessons Other PERSONAL Debt Service Clothing Groceries Haircare Memberships MISCELLANEOUS Child Care Household Help Summer Camp Papers/Books/Magazines Entertainment Pet Expenses Vacations Gifts Legal Fees/Prof. Fees Charitable contributions Children's Parties Children's Allowances Other Child Support Alimony payments Monthly Total $30.00 $225.00 $248.00 Monthly Monthly Children Parent TOTAL MONTHLY EXPENSES $1,980.00 ALEC--O r-w F OF TFE FR TE-'; uTARY 2009 SLE ' -6 PM i : Iv--- 4, CU114-L ? ; ?? JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6751 BRANDEN M. SILKS, : CIVIL ACTION - LAW Defendant : IN DIVORCE INVENTORY OF BRANDEN M. SILKS Defendant 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 (3) years. Defendant verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 41-22'1d9 Brag-den M. Silks, efendant 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. If an item has been appraised, a copy of the appraisal report is attached. (x) 1. Real property (x) 2. Motor vehicles () 3. Stocks, bonds, securities and options O 4. Certificates of Deposit (x) 5. Checking accounts, cash (x) 6. Savings accounts, money market () 7. Contents of safe deposit boxes () 8. Trusts () 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) () 10. Annuities () 11. Gifts () 12. Inheritances () 13. Patents, copyrights, inventions, royalties () 14. Personal property outside the home (x) 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with a company) () 16. Employment termination benefits - severance pay, workman's compensation claim/award () 17. Profit sharing plans () 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 (x) 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 Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any person as of the date this action was commenced. ITEM NUMBER DESCRIPTION OF PROPERTY NAMES OF ALL OWNERS 1 Marital residence located at 200 North Mountain Road Newville, PA 17241 Branden M. Silks & Jessica J. Silks 2 Proceeds from sale of 1997 Volkswagen Jetta Sedan Jessica J. Silks 2 2001 Dodge Ram Branden M. Silks 6 Susquehanna Savings Account Jessica J. Silks 15 Branden Silks Branden M. Silks 19 Susquehanna Bank 401(k) Jessica J. Silks 25 Various personalty Branden M. Silks & Jessica J. Silks NON-MARITAL PROPERTY Defendant lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property. ITEM NUMBER DESCRIPTION REASON FOR OF PROPERTY EXCLUSION 2 2001 Dodge Ram Purchased prior to date of marriage Branden M. Silks and 5 Northwest Bank Checking Deanna Zook Account (post-separation) Branden M. Silks and 6 Northwest Bank Savings Deanna Zook Account (post-separation) PROPERTY TRANSFERRED ITEM DESCRIPTION DATE OF CONSIDERATION TRANSFEREE NUMBER TRANSFER 2 1997 Unknown - Unknown Jessica J. Silks Volkswagen Sold by Jessica J. Jetta Sedan Silks after date of separation LIABILITIES ITEM NUMBER DESCRIPTION CREDITORS DEBTORS 1 Mortgage Susquehanna Bank Branden M. Silks & Jessica J. Silks 1 Home Equity Community Banks Branden M. Silks & Loan #2434711 Jessica J. Silks 2 Refinanced Truck Community Banks Branden M. Silks & Loan #901008357 Jessica J. Silks ($2,500.00 balance) 24 JCPenney's JCPenney's Branden M. Silks & Credit Card Jessica J. Silks 24 Cabela's Cabela's Branden M. Silks VISA #9466 FILED-01:HCE OF THE PR^?"!- r4XARY 2409 SEP -8 Phi E : 53 6 a UIV i tr JESSICA J. SILKS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-6751 BRANDEN M. SILKS, : CIVIL ACTION - LAW Defendant : IN DIVORCE ORDER APPOINTING MASTER AND NOW, 2009, , Esquire is appointed Master with respect to the following claims: equitable distribution. By th p,Wr?oo J. Distribution: essica J. Silks, pro se, 200 North Mountain Road, Newville, PA 17241; Plaintiff "_?ristine Taylor Brann, Esquire, P.O. Box 650, Hershey, PA 17033, (717) 533-3280 (phone); (717) 298-2021 (fax); ctb(a?jsdc.com (e-mail); Attorney for Defendant ?Richard J. Hill and Patricia A. Hill, pro se, 198 North Mountain Road, Newville, PA 17241; Additional Defendants Cumberland County Divorce Master t'ES rr?, ? t ?? RLE - o; X11; f OF THE R"n°° ?,- Ot IOTAQY 2009 S£P 10 AH 9: 10 ~IL~f"SC's ~ ~~ P~"".:~;n~r;7AF~Y Douglas L. Walmer, Esq. Attorney I.D. 89731 Jeffrey A. Keiter, Esq. Attorney I.D. 13966 KEITER 8 WALMER, LLC 226 West Chocolate Ave. Hershey, PA 17033 Tel: (717) 533-8889 Fax: (717) 534-9190 Douglas.walmer~keiterlaw. com JESSICA J. SILKS, Plaintiff v. BRANDEN M. SILKS, Defendant 201D JE;~# 2~+ P!~ 2~ ~ ~ PL,. ~P~YL4'A.!~It~! IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6751 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO WITHDRAW/ENTER APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of JAMES, SMITH, DIETTERICK & CONNELLY, LLP and John J. Connelly, Jr., Esq. and Christine Taylor Brann, Esq. as counsel for BRANDEN M. SILKS, the Defendant, in the above referenced matter. JAMES, SMITH, DIETTERICK & CONNELLY, LLP A Date: By: Christine Taylor Bran squire P.O. Box 650 Hershey, PA 17033 (717) 533-3280 TO THE PROTHONOTARY: Please enter the appearance of KEITER &WALMER, LLC as counsel for BRANDEN M. SILKS, the Defendant, in the above referenced matter. KEITER &WALMER, LLC Date: ~ ~ ~C~ B `~-.~~~ --- Dougla almer, Esq. 226 est Chocolate Ave. Hershey, PA 17033 (717) 533-8889 CERTIFICATE OF SERVICE I, Douglas L. Walmer, Esquire, hereby certify that on the~E~ day of June, 2010 a copy of the foregoing document was served via U.S. First Class Mail, postage prepaid, upon the person named below, in accordance with the applicable rules of procedure, addressed as follows: Jessica J. Silks 200 North Mountain Road Newville, PA 17241 Plaintiff -Pro Se Richard J. Hill and Patricia A. Hill 198 North Mountain Road Newville, PA 17241 Additional Defendants -Pro Se E. Robert Elicker, II 9 Hanover St. Carlisle, PA 17013 Divorce Master _---_ ~-~~ ougl almer, Esq. Attorney I.D. 89731 KEITER & WALMER, LLC 226 West Chocolate Ave. Hershey, PA 17033 Tel: (717) 533-8889 Counsel for Defendant WOLF & WOLF, ATTORNEYS AT LAW NATHAN C. WOLF, ESQ. SUPREME COURT ID N0.87380 SO WEST HIGH STREET CARLISLE PA 17013-2922 717-241-4436 ATTORNEY FOR PLAINTIFF 2010 J(.sL 20 ~~~ I~~ 3 l ~~i~ 1~4 i `; `,tr, ~~ r,r+ ; ~y ~ Le JESSICA J. SILSS, Plaintiff v. BRANDEN M. SILSS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -DIVORCE DOCKET N0.07-6751 PRAECIPE FOR ENTRY OF APPEARANCE OF COUNSEL OF RECORD TO THE PROTHONOTARY: Kindly ENTER the appearance of NATHAN C. WOLF, ESQUIRE, as attorney for the plaintiff, Jessica J. Silks, in this matter. LF, Attorneys at Law Dated: July ~. 2010 Atha Wolf, Esquire 10 est High Street Carlisle, PA 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Plaintiff WOLF & WOLF, ATTORNEYS AT LAW NATHAN C. WOLF, ESQ. SUPREME COURT ID N0.87380 10 WEST HIGH STREET CARLISLE PA 17013-2922 717-241-4436 ATTORNEY FOR PLAINTIFF JESSICA J. SILKS, Plaintiff v. BRANDEN M. SILKS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -DIVORCE DOCSET N0.07-6751 CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, hereby certify that I have served a true and correct copy of the foregoing entry of appearance upon the following person by United States Mail, postage prepaid, and in the matter indicated: Douglas L. Walmer, Esquire Keiter & Walmer, LLC 226 West Chocolate Avenue Hershey, PA 17033 (Counsel for Defendant) Dated: July ~ 2010 Wolf, Esquire est High Street Carlisle, PA 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Plaintiff FILED-OFFICE CF THE PROTHOI oTARY WOLF & WOLF, ATTORNEYS AT LAW NATHAN C. WOLF, ESQ. SUPREME COURT ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013-2922 717-241-4436 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JESSICA J. CLEPPER, (Formerly JESSICA J. SILKS) Plaintiff V. BRANDEN M. SILKS, Defendant CIVIL ACTION - DIVORCE : DOCKET NO. 07-6751 2010 DEC -b PM 1: 52 CUMBERLAND COUNTY PENNSYLVANIA PRAECIPE TO VACATE APPOINTMENT OF DIVORCE MASTER TO THE PROTHONOTARY: An agreement having been reached by the parties resolving the outstanding claim for equitable distribution, kindly forward the instant praecipe requesting that the Court VACATE the appearance of E. Robert Elicker, II, Esquire, as Divorce Master in this matter. Respectfully s WOLF & WQ Dated: December 2010 Natbuk, Wolf, Esquire Attorney for Plaintiff ORDER OF COURT at Law Upon praecipe of counsel, now this _ day of , 2010, the appointment of the E. Robert Elicker, II, Esquire as Divorce Master, as to the sole outstanding claim of equitable distribution, is hereby VACATED. BY THE COURT: J• Distribution: Nathan C. Wolf, Esquire Douglas L. Walmer, Esquire E. Robert Elicker, II, Esquire, Divorce Master WOLF & WOLF, ATTORNEYS AT LAW NATHAN C. WOLF, ESQ. SUPREME COURT ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013-2922 717-241-4436 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JESSICA J. CLEPPER, (Formerly JESSICA J. SILKS) Plaintiff V. BRANDEN M. SILKS, Defendant CIVIL ACTION - DIVORCE DOCKET NO. 07-6751 FILED-OFFICE Cdr THE PROTHONOTARY 2010 DEC -b PM 1:52 'CUMBERLAND COUNTY p i` ENNVYLVANlA 4 PRAECIPE TO VACATE APPOINTMENT OF DIVORCE MASTER TO THE PROTHONOTARY: An agreement having been reached by the parties resolving the outstanding claim for equitable distribution, kindly forward the instant praecipe requesting that the Court VACATE the appearance of E. Robert Elicker, II, Esquire, as Divorce Master in this matter. Respectfully s WOLF & WO Dated: December (2010 Nat6av-e-Wolf, Esquire Attorney for Plaintiff ORDER OF COURT at Law Upon praecipe of counsel, now this __L day of {7kc?, 2010, the appointment of the E. Robert Elicker, II, Esquire as Divorce Master, as to the sole outstanding claim of equitable distribution, is hereby VACATED. tribution: Nathan C. Wolf, Esquire _,--157ouglas L. Walmer, Esquire E. Robert Elicker, II, Esquire, Divorce Master Cor 44.5' r Vint Qc?_ 141 / to BY THE COURT: CD J. = a G'7 -?- . r- --:7j c-7 -v m ? O _C Z ?a C7 2Q ?_T1 CD Dc__ W Dt'i