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HomeMy WebLinkAbout08-0453 JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 24 N. 32ND Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorneys for Plaintiff EARL LEE BEAM, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. L)$ O iq; i Term KATHY A. BEAM, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff EARL LEE BEAM, Plaintiff V. KATHY A. BEAM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION -LAW IN DIVORCE AVISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar acci6n con prontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio o anulamiento puede ser emitado en su contra por la Corte. Una decision puede tambien ser emitida en su contra por caulquier otra queja o compensaction reclamados por el demandante. Usted puede perder dinero, o sus propiedades o otros derechos importantes para usted. Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDO PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 EARL LEE BEAM, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. OF- A. BEAM, CIVIL ACTION - LAW KATHY Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Earl L. Beam, an adult individual who currently resides at 303 Country Club Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Kathy A. Beam, an adult individual who currently resides at 303 Country Club Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 31, 1975, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that there is one (1) minor child of this marriage under the age of eighteen years, namely, Eric M. Beam, born on April 30, 1997. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301(c) of the Divorce Code. Respectfully submitted, JOANNE HARRISON CLOUGH, PC Date: - I - Jo arnson Clough, E (q 're Attorney ID No.: 36461 3 820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff VERIFICATION I, EARL L. BEAM, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. 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: ` C ?3 -,-/ Earl L. Beam C? f'-a ? r,-? c:? ?-u 1 7 ?r ?_ T ? w ? CJ - .o C ... Y b rT? r?.,? ?-< EARL LEE BEAM, Plaintiff V. KATHY A. BEAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-453 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Enter my appearance on behalf of Kathy A. Beam. Papers may be served at the address set forth below. Robert J. Dailey, Esquire O'BRIEN, BARIC & SCHERER 19 W. South Street Carlisle, Pennsylvania 17013 Phone (717) 249-6873 Date: February 14, 2008 Robert J. Dail l, Esq i I.D. No. 20341 19 W. South Street Carlisle, PA 17013 Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that on February 14, 2008, I, Robert J. Dailey, Esquire, of O'BRIEN, BARIC & SCHERER, did serve the Praecipe for Entry of Appearance by first class U.S. mail, postage prepaid, to the party listed below, as follows: Joanne Harrison Clough, Esquire 24 N. 32nd Street Camp Hill, Pennsylvania 17011 (717) 737-5890 Attorney for Plaintiff r-? ?t ? -r? '? -? ?" ^? ? c_- -,; -? ' ? ?_ ?_ ?e?n W "°ti EARL LEE BEAM, Plaintiff V. KATHY A. BEAM, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-453 Civil Term : CIVIL ACTION -LAW : IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Kathy A. Beam, acknowledge that I received and have accepted a true and correct copy of a time stamped Complaint in Divorce filed on January 18, 2008 in the above captioned action by first class mail on the. /1 4 day of February, 2008. Date: - - C eam --t EARL LEE BEAM, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-453 CIVIL TERM KATHY A. BEAM, CIVIL ACTION - LAW Defendant IN DIVORCE PETITION FOR SPECIAL RELIEF PURSUANT TO PA.R.C.P. 1920.43 AND NOW, comes Kathy A. Beam, by and through her attorney, Michael A. Scherer, Esquire, and respectfully represents as follows: 1. The petitioner is the defendant, Kathy A. Beam (hereinafter "wife"), an adult individual residing at 303 Country Club Road, Carlisle, Cumberland County, Pennsylvania (hereinafter "marital residence") 17013. 2. The respondent is the plaintiff, Earl L. Beam (hereinafter "husband"), an adult individual whose legal residence is 303 Country Club Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Husband is represented in this matter by Joanne Clough, Esquire. 4. Husband opposes the relief requested herein. 5. No judge has previously acted in this action. 6. The parties have one chid, Eric Beam, born April 30, 1997, who resides in the marital residence. 7. On February 7, 2008, wife received the divorce complaint husband filed in this matter which came as a complete shock to wife. 8. Since that time, husband has not accounted for his whereabouts, coming and going from the marital residence randomly without notice to wife. r• 9. Husband sleeps at the marital residence through the week but is gone nearly every weekend, sometimes for long weekends. 10. Wife has learned that husband has a girlfriend, with whom he is spending a great deal of time. 11. The parties own a farm in Perry County located at 93 Yankee Drive, New Bloomfield, Pennsylvania. 12. Wife learned recently that husband changed the locks on this property and that husband's girlfriend has numerous items of personal property and clothing located there. 13. Wife believes that Husband intends to move his girlfriend in to the farm. 14. Husband has for some time had a post office box in Mechanicsburg and recently wife learned that some of husband's mail is being forwarded to the farm address. 15. Wife recently filed for child and spousal support and husband has been badgering wife to discontinue the action because he does not want Domestic Relations involved in his financial affairs. 16. Wife is a cafeteria worker at a local school and husband is also telling wife that she needs to get a "real job." 17. Husband was ill and hospitalized within the last few months and husband's girlfriend introduced herself in the hospital as husband's fiance. 18. The parties child, Eric, has expressed confusion and concern about his father's absence and lack of involvement in his life. EXCLUSIVE POSSESSION OF MARITAL RESIDENCE 19. Paragraphs one through eighteen above are incorporated herein by reference. 20. Husband's conduct in coming and going from the marital residence without notice and without regard for his wife and son is disruptive and is creating anxiety within the marital residence. 21. Husband's lack of involvement with his wife and son has had a deleterious effect on the family. 22. Husband's open relationship with another woman has created strife and discord in the marital residence. WHEREFORE, wife respectfully requests that she be granted exclusive possession of the marital residence and that husband be enjoined from removing personal property therefrom except for his personal items and clothing and other items that the parties agree upon in writing. TRANSFER OF MARITAL ASSETS 23. The parties have acquired numerous assets, both financial and tangible. 24. Husband has for many years controlled the assets and has made various purchases and exchanges of assets. 25. Presently, the parties are the owners of tractors, utility trailers, numerous pleasure vehicles, tools, equipment and other such assets. 26. Wife has learned since the filing of the divorce complaint that husband has made a purchases of a hunting cabin and has engaged in other financial transactions that concern her. , v. WHEREFORE, wife requests that this Honorable Court enter an Order preventing the parties from selling, transferring, exchanging or dissipating marital assets without a written agreement or further Order of Court. Respectfully submitted, O'BRIEN, BARIC & SCHERER IA?A-L Date: December 10, 2008 c ael A. Scherer, Esquire I. D. 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dir/domestic/beam-kathy/specialrelief.pet VERIFICATION The statements in the foregoing Petition For Special Relief In The Nature Of Exclusive Possession Of Marital Residence are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn fal ifications to authorities. DATE: t D b Beam CERTIFICATE OF SERVICE I hereby certify that on December 10, 2008, I, Jennifer S. Lindsay, secretary at O'Brien, Baric & Scherer, did serve the Petition For Special Relief Pursuant To Pa.R.C.P. 1920.43, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Joanne Harrison Clough, Esquire 24 North 32"d Street Camp Hill, Pennsylvania 17011 e-„l ` N OA EARL LEE BEAM, Plaintiff V. KATHY A. BEAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-453 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the defendant, Kathy A. Beam. Date: December 10, 2008 I&`4 Michael A. Scherer, Esquire I.D. No. 61974 19 West South Street Carlisle, PA 17013 Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that on December 10, 2008, I, Jennifer S. Lindsay, secretary at O'Brien, Baric & Scherer, did serve the Praecipe for Entry of Appearance by first class U.S. mail, postage prepaid, to the party listed below, as follows: Joanne Harrison Clough, Esquire 24 North 32nd Street Camp Hill, Pennsylvania 17011 '? ? --- _ ?:? = ? ri a?= --i y ?,::'. _ ;w,a r_.. rt=?, .. 't?=; 4 . ? _.?i = ,?, --?; EARL LEE BEAM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-453 CIVIL TERM KATHY A. BEAM, CIVIL ACTION - LAW Defendant IN DIVORCE DEFENDANT KATHY A. BEAM'S ANSWER TO DIVORCE COMPLAINT AND NOW, comes Kathy A. Beam, by and through her attorney, Michael A. Scherer, Esquire, and respectfully represents that: 1. Denied. Although defendant at times sleeps at 303 Country Club Road, Carlisle, Pennsylvania, he often stays elsewhere and receives mail elsewhere. 2.-10. Admitted. COUNTERCLAIM COUNT I - ALIMONY 11. Paragraphs one through ten above are incorporated herein by reference. 12. Defendant will be unable to provide for her reasonable needs following the divorce unless Plaintiff is directed to pay her alimony. 13. Plaintiff's income is substantially higher than Defendant's income and Plaintiff is able to pay Defendant alimony. WHEREFORE, Defendant requests that the Court award her permanent alimony. COUNT II - APL, COUNSEL FEES, COSTS & EXPENSES 14. Paragraphs one through thirteen above are incorporated herein by reference. 15. Plaintiff's income is much higher than Defendant's income. 16. Defendant will be unable to sustain herself and employ counsel without an award of alimony pendente lite. WHEREFORE, Defendant requests that the Court award her alimony pendente lite, counsel fees, costs and expenses. Respectfully submitted, O'BRIEN, BARIC & SCHERER 4-, kIA ? (, Mich el A. Scherer, Esquire Date: December 10, 2008 I.D. 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Defendant mas.dir/domestic/beam-kathy/divorcecomplaint.ans VERIFICATION I verify that the statements made in the foregoing Defendant Kathy A. Beams' Answer To Divorce 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. I undersigned that false statements herein are made subject to penalties of 18 Pa.C.S. §4904, relating to unsworn falsifications to authorities. Date: December 10, 2008 Mich I A. Scherer, Esquire CERTIFICATE OF SERVICE I hereby certify that on December 10, 2008, I, Jennifer S. Lindsay, secretary at O'Brien, Baric & Scherer, did serve Defendant Kathy A. Beams' Answer To Divorce Complaint, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Joanne Harrison Clough, Esquire 24 North 32"d Street Camp Hill, Pennsylvania 17011 7 ?^S`1 -'? ? ;,? ??? ???? L a ? t ?? ,,` _\ .. ,s° S`°'3 t>c . .'.? =? r c? > EARL LEE BEAM, IN THE COUF Plaintiff CUMBERLAN V. NO. 2008-453 KATHY A. BEAM, CIVIL ACTIOt Defendant IN DIVORCE ORDER OF COURT AND NOW, this day of within Petition For Special Relief Pursuant To Pa.R.C. matter for the , day of _ '200 Courtroom No._,2bf the Cumberland County Court /Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 /Joanne Harrison Clough, Esquire 24 North 32nd Street Camp Hill, Pennsylvania 17011 Cc? l_ r 1 1211e, DEC 15 20M 6 -7- T OF COMMON PLEAS OF COUNTY, PENNSYLVANIA CIVIL TERM - LAW 2008, upon consideration of the 1920.43, a hearing is set in this S. `f5 ?a-'./pew. in at use, Carlisle, Pennsylvania. J. >-- -D cr fr T- LsLJ c:) ti EARL LEE BEAM, Plaintiff V. KATHY A. BEAM, Defendant RE U ALAI IN THE COURT F COMMON PLEAS OF CUMBERLAND OUNTY, PENNSYLVANIA NO. 2008-453 C VIL TERM CIVIL ACTION LAW IN DIVORCE AND NOW, comes Kathy A. Beam, by and through her attorney, Michael A. Scherer, Esquire, and respectfully requests that Domestic Relations schedule a hearing on the claim for alimony pendente lite raised in Defenda is Counterclaim. The Defendant, Kathy A. Beam, has or will file a request for a hearing de novo before the Support Master to PACSES Case Number 022110464 and she respectfully requests that this request for a hearing be heard by the Support Master, at which time the request for spousal support will be withdrawn. Respectfully submitted, O'BRIEN, BARIC-f & SCHERER Date: December 16, 2008 Michael-A. Scherer, Esquire I.D. 61974 19 West South Street Carlisle, ennsylvania 17013 (717) 24 -6873 Attorney (for Defendant mas.dirldomestic/beam-kathy/aplhearing request.pid . -„_ I hereby certify that on December 16, 2008, I, Jen?ifer S. Lindsay, secretary at O'Brien, Baric & Scherer, did serve Defendant Kathy A. Beams Request for Hearing by first class U.S. mail, postage prepaid, to the party listed Below, as follows: Joanne Harrison Clough, Es uir 24 North 32nd Street Camp Hill, Pennsylvania 17011 S. tF?. ?J r? c yi ?'? In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION KATHY A. BEAM ) Docket Number 08-453 CIVIL Plaintiff ) VS. ) PACSES Case Number 402110554 EARL L. BEAM ) Defendant ) Other State ID Number ORDER OF COURT You, KATHY A. BEAM plaintiff/defendant of 303 COUNTRY CLUB RD, CARLISLE, PA. 17015-8881-03 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the FEBRUARY 10, 2009 at 10:30AM fora hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 r BEAM v• BEAM PACSES Case Number: 402110554 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: a.. - p$ JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. 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 CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. Service Type M Worker ID 21302 ? ??"1 .? ?`=" ' _?? t T 3 ?: .._ ... lp -- "Y? ?' ??? ? -?'? ?'?`` ? r _, ?,ti ?} r- -? In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION KATHY A. BEAM ) Docket Number 08-453 CIVIL Plaintiff ) VS. ) PACSES Case Number 402110554 EARL L. BEAM ) Defendant ) Other State ID Number ORDER OF COURT You, EARL L. BEAM plaintiff/defendant of 93 YANKEE DR, NEW BLOOMFIELD, PA. 17068-8049-93 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the FEBRUARY 10, 2009 at 10:3 0AM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 r' BEAM V. BEAM PACSES Case Number: 402110554 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: P-1? -03 f JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. 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 CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. 1 Service Type M Worker ID 21302 ?+ ,? -'?' : _ ? ?' ? . L ,,,,. .,.. a EARL LEE BEAM, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KATHY A. BEAM, ; DEFENDANT 08-453 CIVIL TERM ORDER OF COURT AND NOW, this 2-c? day of December, 2008, upon representation by counsel that the parties have reached a settlement, the hearing scheduled for December 31, 2008, on a petition by defendant for special relief, IS CANCELLED. oanne Harrison Clough, Esquire For Plaintiff ,.,k Kichael A. Scherer, Esquire For Defendant :sal A EdgarB. Bayley, J. ?? >... ?.. ??- _t: c?;,, .._.. _,,,,,,.?.-r -- Fa.:. ? r- _. _ 0 +.. ? ) v { '"S- L ?' ?-- t? _. Lt_ c? x EARL LEE BEAM, Plaintiff V. KATHY A. BEAM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-453 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE Please withdraw my appearance on behalf of the Defendant, Kathy A. Beam, in the above-captioned matter. `Z19k-, Micha A. cherer, squire Date: Z. 23. n9 PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of the Defendant, Ka m, in the above-captioned matter. 'harles Rector, quire - 1104 Femwoo Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Date: 3 -? [S ? _t EARL L. BEAM, IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-453 CIVIL TERM KATHY A. BEAM, IN DIVORCE Defendant/Petitioner PACSES CASE: 402110554 ORDER OF COURT AND NOW to wit, this 16th day of March 2009, it is hereby Ordered that the Petition for Alimony Pendente Lite is withdrawn, without prejudice, pursuant to the written request of the Petitioner, dated February 6, 2009. This Order shall become final twenty (20) days after the mailing of the notice of the entry of the order to the parties unless either parry files a written demand with the Domestic Relations Section for a hearing de novo before the Court. BY THE COURT: Edward E. Guido, J. DRO: R.J. Shadday xc: Petitioner Respondent Michael A. Scherer, Esq. Joanne Clough, Esq. Service Type: M Form OE-001 Worker: 21005 92/06/2009 16:27 7172495755 OBS rWtat ni Law O,,icaa 0IRMEN, BARTCdo SCOMWR 19 west south street Caritsle, Aemtsylvania 17013 Robert L. O'Brien David A. Baric Michael A. Scherer COPY (717) 249-6873 Fax: (717) 249-5751 Email: m=hertrCalobsIaw.cotI February 6, 2009 VIA FA SIMILE ONLY TO, (7171240-7777 Michael R. Rundle, Esquire Support Mastrir 9 North Hanover Street Carlisle, Pennsyhrania 17013 4D z I b j55 RE: Beam vs. Beam PACSES 0 022110464 Dear Mr. Rundle: As a follow-up to my earlier letter to you today, please swept this letter as my notice that the request for the hearing on APL also be withdrawn without pr+ejudioe and that the hearing on the APL matter scheduled for February 10, 2009 also be canceled. Joanne Clough, Esquire, concurs in this request. Please contact me If you have any questions or concerns. MAS/ar cc: Joanne Clough, Esquire Kathy Beam File Very truly yours, O'BRIEN, BARIC & SCHER9R Schenk Michael A . rn"A'rl - nostiallmm/rundleM CL- Ck-- H L,,1 EARL LEE BEAM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-453 CIVIL TERM KATHY A. BEAM, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. Notices of intent to serve subpoenas with a copy of the subpoenas attached thereto were mailed to Plaintiff s counsel at least twenty (20) days prior to the date on which the subpoenas are sought to be served, 2. Copies of the Notices of intent, including the proposed subpoenas, are attached to this certification, 3. No objection to the subpoenas has been received, and 4. The subpoenas which will be served are identical to the subpoenas attached to this Notice. RESPECTFULLY SUBMITTED: Charles Rectof, Esquile-(ID # 39121) 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Date: ??f U EARL LEE BEAM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-453 CIVIL TERM KATHY A. BEAM, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS & THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Kathy A. Beam, Defendant, intends to serve subpoenas identical to the five (5) that are attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena(s). If no objection(s) is made, the subpoenas may be served. BY: CMIes Rector, Esquire (?D # 39121) 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Date: c J? ?' 1 EARL LEE BEAM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-453 CIVIL TERM KATHY A. BEAM, CIVIL ACTION -LAW Defendant IN DIVORCE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO R ULE 4009.22 To: M&T Bank 1 M&T Plaza Buffalo, NY 14203 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Copies of account statements, including canceled checks, for any and all accounts in which Earl Lee Beam is/was a named owner, from January 2005 to the present, at the Law Offices of Charles Rector, Esquire, P.C., 1 104 Fernwood Avenue, Ste. 203, Camp Hill, PA 17011-6912. You may deliver or mail legible copies of the documents or produce things requested by this Subpoena. together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fai I to produce the documents or things required by this Subpoena within twenty (20) days after its service, the party serving this Subpoena may seek a court order compelling you to comply with it. This Subpoena was issued at the request of the following person: Charles Rector, Esquire -- ID No. 39121 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Defendant BY THE COURT: Prothonotary/Clerk, Civil Division Date: Deputy EARL LEE BEAM, Plaintiff V. KATHY A. BEAM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-453 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVER Y PURSUANT TO RULE 4009.22 To: Members 151 Federal Credit Union 5000 Louise Drive/PO Box 40 Mechanicsburg, PA 17055 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Copies of account statements, including canceled checks, for any and all accounts in which Earl Lee Beam is/was a named owner, from January 2005 to the present, at the Law Offices of Charles Rector, Esquire, P.C., 1104 Fernwood Avenue, Ste. 203, Camp Hill, PA 17011-6912. You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena within twenty (20) days after its service, the party serving this Subpoena may seek a court order compelling you to comply with it. This Subpoena was issued at the request of the following person: Charles Rector, Esquire -- ID No. 39121 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Defendant BY THE COURT: Prothonotary/Clerk, Civil Division Date: Deputy EARL LEE BEAM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-453 CIVIL TERM KATHY A. BEAM, CIVIL ACTION -LAW Defendant IN DIVORCE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: PNC Bank One PNC Plaza 249 Fifth Avenue Pittsburg, PA 15222-2707 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Copies of account statements, includinp, canceled checks, for any and all accounts in which Earl Lee Beam is/was a named owner, from Januarv 2005 to the Present, at the Law Offices of Charles Rector, Esquire, P.C., 1104 Fernwood Avenue, Ste. 203, Camp Hill, PA 17011-6912. You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena within twenty (20) days after its service, the party serving this Subpoena may seek a court order compelling you to comply with it. This Subpoena was issued at the request of the following person: Charles Rector, Esquire -- ID No. 39121 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Defendant BY THE COURT: Prothonotary/Clerk, Civil Division Date: Deputy EARL LEE BEAM, Plaintiff V. KATHY A. BEAM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-453 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO R ULE 4009.22 To: Orrstown Bank 77 E. King Street Shippensburg, PA 17257 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Copies of account statements, including canceled checks, for any and all accounts in which Earl Lee Beam is/was a named owner, from January 2005 to the present, at the Law Offices of Charles Rector, Esquire, P.C., 1104 Fernwood Avenue, Ste. 203, Camp Hill, PA 17011-6912. You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena within twenty (20) days after its service, the party serving this Subpoena may seek a court order compelling you to comply with it. This Subpoena was issued at the request of the following person: Charles Rector, Esquire -- ID No. 39121 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Defendant BY THE COURT: Prothonotary/Clerk, Civil Division Date: Deputy EARL LEE BEAM, Plaintiff V. KATHY A. BEAM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-453 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Sovereign Bank P. O. Box 12646 Reading, PA 19612 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Copies of account statements, including, canceled checks, for any and all accounts in which Earl Lee Beam is/was a named owner, from January 2005 to the present, at the Law Offices of Charles Rector, Esquire, P.C., 1 104 Fernwood Avenue, Ste. 203, Camp Hill, PA 17011-6912. You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena within twenty (20) days after its service, the party serving this Subpoena may seek a court order compelling you to comply with it. This Subpoena was issued at the request of the following person: Charles Rector, Esquire -- ID No. 39121 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Defendant BY THE COURT: Prothonotary/Clerk, Civil Division Date: Deputy V F EARL LEE BEAM, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-453 CIVIL TERM KATHY A. BEAM, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS & THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Kathy A. Beam, Defendant, intends to serve a subpoena identical to the one attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoenas may be served. BY: f Charles Rector,-Esquire-(ID # 39121) 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Date: C )_3 c r EARL LEE BEAM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-453 CIVIL TERM KATHY A. BEAM, CIVIL ACTION -LAW Defendant IN DIVORCE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVER Y PURSUANT TO RULE 4009.22 To: Edward Jones P.O. Box 66906 St. Louis, MO 63166-6906 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Copies of all monthly account statements for any and all accounts in which Earl Lee Beam is/was a named owner, from January 2005 to the present, at the Law Offices of Charles Rector, Esquire, P.C., 1104 Fernwood Avenue, Ste. 203, Camp Hill, PA 17011-6912. You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena within twenty (20) days after its service, the party serving this Subpoena may seek a court order compelling you to comply with it. This Subpoena was issued at the request of the following person: Charles Rector, Esquire -- ID No. 39121 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Defendant BY THE COURT: Prothonotary/Clerk, Civil Division Date: Deputy CERTIFICATE OF SERVICE I, Tammy Faust, Paralegal for Charles Rector, Esquire, do hereby certify that on the 15th day of July, 2009, I caused a true and correct copy of the within Certificate Prerequisite to Service of Subpoenas Pursuant to Rule 4009.22 to be served upon Plaintiff's counsel by depositing same in first class, United States mail, postage paid, in Camp Hill, Pennsylvania: Joanne Harrison Clough, Esquire 3820 Market Street Camp Hill, PA 17011 By: G _ Tammy S. F st Law Offices of Charles Rector, Esquire, P.C. 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Date: 7 ?J /?7 PL E-, OF ? , ,; ??