Loading...
HomeMy WebLinkAbout08-1914 TERI L. ILGEN, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0$ - /QIY Civil Term BERNARD A. ILGEN, Defendant CIVIL ACTION - LAW 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE, THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 TERI L. ILGEN, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA BERNARD A. ILGEN, Defendant : NO. Civil Term CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE COUNT I - DIVORCE 1. Plaintiff is Teri L. Ilgen, a competent adult individual, who resides at 8 Hope Terrace, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Bernard A. Ilgen, a competent adult individual, whose address is 933 S. Michael Road, St. Mary's, Pennsylvania, 15857. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 7, 2001 in Clearfield County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) that the marriage is irretrievably broken pursuant to 23 Pa.C.S. 3301(c); WHEREFORE, Plaintiff requests the court to enter a Decree in divorce. COUNT II - EQUITABLE DISTRIBUTION OF PROPERTY 11. Paragraphs 1 - 10 are herein incorporated by reference. 12. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. Respectfully Date: -j 0?7 v?/ yin Adams, Esquire I.D. No. 79465 17 . South St. 4arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Complaint 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: 3 /,-? //Qs j f Teri L. Ilgen, Plaintiff "'7T 1= " ? DO 'yA) ?Y TERI L. ILGEN, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA BERNARD A. ILGEN, Defendant : NO.O S r /Vy Civil Term CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated on September 1, 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: j6t"?- r Teri L. Ilgen, Plaintiff n C=t y C ? r l C" TERI L. ILGEN, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 1914 Civil Term BERNARD A. ILGEN, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE REGARDING THE AFFIDAVIT OF SEPARATION AND NOW, this April 12, 2008, I, Jane Adams, Esquire, hereby certify that on January 25, 2008, a certified true copy of the NOTICE TO DEFEND, COMPLAINT, AND AFFIDAVIT OF SEPARATION were served upon the following person, via certified mail, return receipt requested at the following address: Bernard Ilgen COMPLETE 933 S. Michael Road 15857 Pa Mary's St ¦ Complete items 1, 2, and 3. Also complete liver is desired t ted D 4 if R i it A. Signature ? Agent , . . DEFENDANT . r es c e y em ¦ Print your name and address on the reverse X 25? ? Addressee so that we can return the card to you. E,, eived by ( P ted Name) _ ate , slivery ¦ Attach this card to the back of the mailpiece, or on the front if space permits. D. Is delivery address different f mYes =, 1. Article Addressed to: If YES, enter delivery addre low: No 6e_rnoa.rd Il 2n z ? D q3-5 S . M;, el Roac1 mf 5 y Pa I Sgs7 3. $e ice Type U ertified Mail ? Express Mail ? Registered 3R::?eturn Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7003 2260 (Transfer from service labs! 0000 8703 0259 PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1035 Respectfully Submitted: J e Adams, Esquire No. 79465 77 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ?.._,, c^.? ? { (? ? __. ^ w*,? .. fir: t.? TERI L. ILGEN, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008 - 1914 Civil Term BERNARD A. ILGEN, Defendant CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Defendant moves this Court to appoint a master with respect to the following claims: (j Divorce Distribution of Property ( ) Annulment ( ) Support ( ) Alimony ( ) Counsel fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery is substantially complete as to the claim(s) for which the appointment of a master is requested. (2) The Defendant is: PRO SE. (3) The statutory ground(s) for divorce is 3301 (d). (4) Delete the inapplicable paragraph(s): (b) An agreement has been reached with respect to the following claims: NONE. (c) The action is contested with respect to the following claims: ALL. (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take one half day. (7) Additional information, if any, relevant to the motion: NONE. Date: 5 01.30$` l ieAddaams, Esquire 7 South St. Carlisle, Pa. 17013 Attey for Plaintiff (717) 245-8508 ORDER APPOINTING MASTER AND NOW, this , 2008, Robert Elicker, Esquire, is appointed following claims: ALL. ppointed Master with respect to the BY THE COURT: J. r- r a "_s } J-1 TERI L. ILGEN, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA BERNARD A. ILGEN, Defendant NO. 2008 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Defendant moves this Court to appoint a master with respect to the following claims: Divorce Distribution of Property ( ) Annulment ( ) Support ( ) Alimony ( ) Counsel fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery is substantially complete as to the claim(s) for which the appointment of a master is requested. (2) The Defendant is: PRO SE. (3) The statutory ground(s) for divorce is 3301 (d). (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the following claims: NONE. (c) The action is contested with respect to the following claims: ALL. (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take one half day. (7) Additional information, if any, relevant to the motion: NONE. Date: 5/a3/69 e Adams, Esquire 7 W. South St. Carlisle, Pa. 17013 Attorney for Plaintiff (717) 245-8508 ORDER APPOINTING MASTER AND NOW, this 008, Robert Elicker, Esquire, is appointed Master with respect to the following claims: ALL. BY oHE COUR J. 110 o +cC X S a° 4= CV i V V < ?Kf?' TERI L. ILGEN, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA BERNARD A. ILGEN, Defendant : NO. 2008 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME, To the Prothonotary- Notice is hereby given that the Plaintiff in the above matter: _X_ prior to the entry of a Final Decree in divorce. OR - after the entry of a Final Decree in Divorce hereby elects to resume the prior surname of PARANA avowing her intention pursuant to the provisions of 54 P.S. s704. Date: 1 0 Teri L. Ilgen ?y ??M- -4 Pri r Name Teri L. Parana Signature of Name being resumed. COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND )as ) On this, the I day of krL4.,11J2,? , 2008 before me, the undersigned officer, personally appeared TERI L. ILGEN/TERI L. PARANA personally known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and offi ' 1 seal. COMMONWEALTH OF PENNSYLVANIA NotwW seat Public Jam Ad M& Nowy mic Emyc arlisle BOM erIVA can* Conanssion Expires Sept. 6, 2008 commission expires: K, k,4 Q e°; TERI L. ILGEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 1914 Civil Term BERNARD A. ILGEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE MOTION TO COMPEL DISCOVERY AND NOW COMES, the Plaintiff, Teri L. Ilgen, now known as Teri L. Parana, by and through her Attorney, Jane Adams, Esquire, and moves this Honorable Court as follows: 1. Plaintiff, Teri L. Parana, (hereinafter referred to as "Wife"), and Defendant, Bernard A. Ilgen, (hereinafter referred to as "Husband") were married on May 7, 2001. 2. The above-captioned action was initiated by Wife filing a Complaint in Divorce on March 26, 2008, which contained a claim for Equitable Distribution. 3. On May 29, 2008, a Motion to Appoint the Master in the above-captioned case was filed. 4. On June 25, 2008, Wife's attorney signed a discovery certification indicating that it was anticipated that discovery would be complete within approximately two weeks. 5. On July 22, 2008, Wife's attorney completed and forwarded a Request for Production of Documents and Interrogatories to Husband. 6. Husband has not responded to Wife's Interrogatories or Request for Production of Documents. 7. On August 30, 2008, Wife's attorney wrote Husband again requesting such information. 8. Husband has not responded via mail, or phone call to Wife or Wife's Attorney regarding the requests for information. 9. Husband never requested an extension of time to complete and return the Request for Production of Documents and Interrogatories. 10. Wife is requesting that Husband be ordered to provide such information, or that an order authorize Wife to obtain such information regarding Husband's assets and retirement directly from Husband's employment. 11. Wife knows of no reasonable basis for Husband's delay in providing the requested information other than to delay the Divorce. 12. Husband is pro se and has not responded to any letters or requests for information; therefore is it assumed that Husband is not in agreement with Wife's request. 13. There is no previously assigned Judge in this matter. 14. After her numerous requests, Wife still has not been provided the requested information and knows of no other alternative than to request that the Court order discovery of this information. WHEREFORE, Wife respectfully moves this Honorable Court for the entry of an Order Compeling Discovery in the above-captioned matter as well as any other relief, such as Attorney's Fees, that this Honorable Court may deem appropriate and necessary. Date: ne Adams, Esquire 7 W. South St. r7 Carlisle, Pa. 17013 (717) 245-8508 I.D. No. 79465 Attorney for Plaintiff z TERI L. ILGEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 1914 Civil Term BERNARD A. ILGEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Jane Adams, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing MOTION TO COMPEL DISCOVERY, in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Bernard Alan Ilgen 933 S. Michael St. St. Mary's, Pa. 15857 DEFENDANT DATED: ? vU Ja Adams, Esquire 17 South St. lisle, Pa. 17013 7) 245-8508 ornev for Plaintiff '. o r rT- "t''f a TERI L. ILGEN, V. Plaintiff BERNARD A. ILGEN, Defendant SFP 0 8 2008 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this 10 Day of < , 2008, upon consideration of Defendant's Motion to Compel Discovery and the Plaintiff's response: A hearing hereon is scheduled for the I-A day of C> w , 20 _, at ?• 0 io W!/P.M in Courtroom N03 of the Cumberland County Courthouse in Carlisle, Pennsylvania. J. cc: /Jane Adams, Esquire -//Bernard Ilgen, Defendant, pro se 7110168 vI I TERI L. ILGEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 1914 Civil Term BERNARD A. ILGEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this October 8, 2008, I, Jane Adams, Esquire, hereby certify that on or about September 23, 2008, a certified true copy of the ORDER setting a hearing on Defendant's Motion to Compel Discovery was served upon the Defendant, via certified mail, restricted delivery, return receipt requested at the following address: Bernard Ilgen 933 S. Michael Road St. Mary's, Pa. 15857 DEFENDANT ¦ CZmPlet® items 1, 2, and 3. Also complete item 4 If Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpleoe, or on the front If space permits. A mgnamrs, X ? Agent y? ? Addressee 8.?R5ewedbC*fntsd ) C. Date of Delivery D. Is delb w F at( na different fiom Item 1? ? Yes If YES, enter delivery address below: ? No ' 3, Swim Type AhCatifled Mall ? Express mail ? Registered Nkastum Receipt for Mwehandiae ? insured mail ? C.O.D. 4. Restricted Delivery? (F.xha roe) ? Yea M6ft .Oonr.@rW=, Uf # 7008 1140 0001 6164 4100 1. Article Addressed to: &-mard D en Q3 s.M1ch?e 1 Rcxkd 3 -. N1ar s DA , sus 7 PS Fame 3811, February 2oo4 . Dornesfo f+saan Raoelpt Respectfully Sub Ja Adams, C-squire'v I. o. 79465 17 . South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF tamese.ea.M.?p ?- Jane Adams ATTORNEY AT LAW 17 WEST SOUTH STREET CARLISLE, PA. 17013 (717) 245-8508 voice (717) 241-2456 esgadams@gmail.com VIA CERTIFIED MAIL September 18, 2008 Bernard llgell 933 S. Michael Road St. Mary's, Pa. 15857 Re: Ilgen v. llgen No. 2008 - 1914 (Cumberland County). Dear Mr. Ilgen: Enclosed please find a certified copy of the Order setting a hearing on this matter for October 9"' 2008 at 3:00 p.m. in Courtroom No. 3 of the Cumberland County Courthouse. Thank you for your attention to this matter. Very truly yours, r C? . Jon. Adams, Esquire 4 cc: reri Parana ;--, rv C > co r ,. - F TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1914 CIVIL TERM BERNARD A. ILGEN, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER OF COURT AND NOW, this 9th day of October, 2008, the Defendant is directed to respond to the discovery requests within 10 days of receipt of this Order or to suffer appropriate sanctions. By Edward E. Guido, J. .Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 F9r the Plaintiff Bernard A. Ilgen 933 South Michael Street St. Mary's, PA 15857 Defendant, Pro se srs Co es rn c-U LL !o/131D9 tz/? VINYAWNN3d AJNnoo ?'w.ns t l L l t i ! Wit E ! DOW iowH. W:Hi TERI L. ILGEN, V. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA BERNARD A. ILGEN, Defendant NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE MOTION TO COMPEL DISCOVERY AND NOW COMES, the Plaintiff, Teri L. Ilgen, now known as Teri L. Parana, by and through her Attorney, Jane Adams, Esquire, and moves this Honorable Court as follows: 1. Plaintiff, Teri L. Parana, (hereinafter referred to as "Wife"), and Defendant, Bernard A. Ilgen, (hereinafter referred to as "Husband") were married on May 7, 2001. 2. The above-captioned action was initiated by Wife filing a Complaint in Divorce on March 26, 2008, which contained a claim for Equitable Distribution. 3. On May 29, 2008, a Motion to Appoint the Master in the above-captioned case was filed. 4. On June 25, 2008, Wife's attorney signed a discovery certification indicating that it was anticipated that discovery would be complete within approximately two weeks. 5. On July 22, 2008, Wife's attorney completed and forwarded a Request for Production of Documents and Interrogatories to Husband. 6. Husband has not responded to Wife's Interrogatories or Request for Production of Documents. 7. On August 30, 2008, Wife's attorney wrote Husband again requesting such information. 8. Husband has not responded via mail, or phone call to Wife or Wife's Attorney regarding the requests for information. 9. Husband never requested an extension of time to complete and return the Request for Production of Documents and Interrogatories. 10. Wife knows of no reasonable basis for Husband's delay in providing the requested information other than to delay the Divorce. 11. On September 5, 2008, Wife filed a Motion to Compel Discovery. 12. On October 9, 2008, after a brief hearing, Husband was directed to respond to the Wife's discovery requests within 10 days of receipt of the Court's Order. A copy of the Court's Order of October 9, 2008 is attached as Exhibit A. 13. Wife's counsel sent Husband a copy of the Order via certified mail. On October 20, 2008, Husband received a copy of the Order. A copy of the letter and return receipt is attached as Exhibit B. 14. Wife is requesting the following sanctions: (a) That Wife's counsel be authorized, by court Order, to directly obtain information as requested in her Interrogatories, from Husband's employer or from any other entity or person having such relevant information. (b) That Husband be required to pay attorney's fees to Wife in the amount of $1000.00 within thirty (30) days due to the fact that such fees were incurred as a direct result of Husband not cooperating with Wife's discovery requests. 15. This matter was previously assigned to Judge Guido. 16. Wife's counsel has had no communication from Defendant; therefore, it is assumed Defendant is not in agreement with the relief requested in this Motion. WHEREFORE, Wife respectfully moves this Honorable Court for the imposition of Sanctions. Date: ` d 3a 0 9 J ne Adams, Esquire 1 W. South St. arlisle, Pa. 17013 717) 245-8508 I.D. No. 79465 Attorney for Plaintiff TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1914 CIVIL TERM BERNARD A. ILGEN, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER OF COURT AND NOW, this 9th day of October, 2008, the Defendant is directed to respond to the discovery requests within 10 days of receipt of this Order or to suffer appropriate sanctions. By the Cqu-rt ?r Edward E. Guido, J. jwe Adams, Esquire est South Street Carlisle, PA 17013 For the Plaintiff Bernard A. Ilgen 933 South Michael Street St. Mary's, PA 15857 Defendant, Pro se srs 161, in- 1 r-T u ;'r":?s 5? 1 ??•? ?.j? eeu,ilC 1i'! p? bid L.! Jane Adams ATTORNEY AT LAW 17 WEST SOUTH STREET CARLISLE, PA. 17013 (717) 345-8508 voice (717) 24"1-2456 esgadams@gmail.com VIA CERTIFIED MAIL October 18, 2008 Bernard 11L- ,,en 933 S. Michael Road St. Ivtary's, Pa. 15857 Re: fl-en v. 11gen No. 1)008 - 1914 (Cumberland County). Lear Mr. llgen: 1 nclosed please find a certified copy of the Order issued by Judge Guido after our October 9" hearing. Thank You tYll" yoU1- attention to this matter. Very truly yours, Jane Vams. I;scluiIV cc: Teri Parana v f1-f--Xft,9 lT 9 7008 1140 0001 6163 2978 u an 'm o ° , A • mF D a 2 • o ra .o a ro u? $ {fl to ? ? i ¦ Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you, ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: X33 S. (;0? S IS?? A. Signat O' r \ ?"A ? Agent X ? Addressee B. Received by (PrYlited Name) C. at of Delivery .00 (S D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3, Service Type Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number ?008 1140 0001 6163 2 9 7 8 (Transfer from service Mabee PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-154( TERI L. ILGEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 1914 Civil Term BERNARD A. ILGEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Jane Adams, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing MOTION, in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Bernard Alan Ilgen 933 S. Michael St. St. Mary's, Pa. 15857 DATED: L / 30 "S 1300 /Jane Adams, Esquire 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff i7 NOV n 3 2008( TERI L. ILGEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 1914 Civil Term BERNARD A. ILGEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE ORDER OF COURT AND NOW, this V A Day of &4 V j,#4L4 , 2008, upon consideration of Defendant's Motion to for Sanctions, a Rule is issued upon Defendant, Bernard A. Ilgen to show why the relief requested should not be granted. Such Rule is returnable in /V days 910v ? • J. cc: Jane Adams, Esquire op C.? t c4 Bernard Ilgen, Defendant, pro se SP,044d `" l :O HV S- AON goof A8VIC -40miC)dd 3HI JQ TERI L. ILGEN, V. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA BERNARD A. ILGEN, Defendant NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE MOTION TO MAKE RULE TO SHOW CAUSE ABSOLUTE AND NOW COMES, the Plaintiff, Teri L. Ilgen, now known as Teri L. Parana, by and through her Attorney, Jane Adams, Esquire, and moves this Honorable Court as follows: 1. Plaintiff, Teri L. Parana, (hereinafter referred to as "Wife"), and Defendant, Bernard A. Ilgen, (hereinafter referred to as "Husband") were married on May 7, 2001. 2. The above-captioned action was initiated by Wife filing a Complaint in Divorce on March 26, 2008, which contained a claim for Equitable Distribution. 3. Pursuant to Wife's previous Motion to Compel Discovery and Motion for Sanctions, an Order was entered on November 4, 2008, which provided that Wife's request for relief would be granted if Defendant did not respond within ten (10) days. A copy of that Order is attached as Exhibit A. 4. Wife's attorney sent Defendant a copy of this Order via certified mail. A copy was also sent via regular mail from the Prothonotary. 5. The certified mail was returned, and as Defendant never picked up or signed for the certified mail. A copy of the return envelope is attached as Exhibit B. 6. On December 9, 2008, Wife's attorney sent a copy of the Order, via regular mail, to Defendant. A copy of the certificate of mailing is attached as Exhibit C. As of the date of this petition, the regular mail was not returned. 7. Ten days have passed since the Rule was served on Defendant. 8. Due to Husband's lack of cooperation, Wife has incurred Attorney's fees, a copy of which are detailed in Exhibit D, which is attached. 9. Husband has not responded via mail, or phone call to Wife or Wife's Attorney regarding the requests for information. 10. Wife knows of no reasonable basis for Husband's delay in providing the requested information other than to delay the Divorce. 11. Wife is requesting the following sanctions: (a) That Wife's counsel be authorized, by court Order, to directly obtain information as requested in her Interrogatories, from Husband's employer or from any other entity or person having such relevant information. (b) That Husband be required to pay attorney's fees to Wife in the amount of $629.00 within thirty (30) days due to the fact that such fees were incurred as a direct result of Husband not cooperating with Wife's discovery requests. 12. This matter was previously assigned to Judge Guido. 13. Wife's counsel has had no communication from Defendant; therefore, it is assumed Defendant is not in agreement with the relief requested in this Motion. WHEREFORE, Wife respectfully moves this Honorable Court for the imposition of Sanctions. Date: 3a 6 By: arks, Esquire a W. South St. rlisle, Pa. 17013 (717) 245-8508 I.D. No. 79465 Attorney for Plaintiff r? NOV n .9 20086 TERI L. iLGEN, V. Plaintiff BERNARD A. ILGEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this 1 1?6 Day of &j V L 2008, upon consideration of Defendant's Motion to for Sanctions, a Rule is issued upon Defendant, Bernard A. Ilgen to show why the relief requested should not be granted. Such Rule is returnable in /0 days J. CC'. Jane Adams, Esquire Bernard Ilgen, Defendant, pro se FRUE COPY FROM RECURU i Tesbmony whereof, l herd unto set my hand i0 they sal Of said Court at Carlisle, k ofd, PraRAa?at?r? ?1crh? ?r ?- Jane Adarns ATTORNEY AT LAW 17 W IESI' SOUTH SZREE'r CARLISI-1, PA. 17013 (717) 245-8508 voice (717) 241-2456 esgadams@gmail.com VIA CERTIFIED MAIL November 6, 2008 Bernard Ilgen 933 S. Michael Road St. Mary's, Pa. 15857 Re: 11gen v. ilgen No. 2008 - 1914 (Cumberland County). Dear Mr. Ilgen: Fnclosed please find another copy ol'the Motion for Sanctions and a certified copy of the Rule to Show Cause issued by Judge Guido on November 5, 2008. 't'hank you for your attention to this matter. Very truly yours, cc: Teri Parana n Adams. Usggire 10 E\1 h-, (? a-B 1 ?f r} .~+ 0 7 T/ [L r- v r ?.n i 3 C3 - 3 _._--- o _ Er =- i r v N ._a O W !? M lJl O/" y? © ZAIQ - N fc ? a t .. N ' 1 ?+ C s s TERI L. ILGEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V ; NO. 08 - 1914 Civil Term BERNARD A. ILGEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Jane Adams, Esquire, do hereby certify that on this date, I served a true and correct copy of the November 4, 2008 ORDER in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: U.S. POSTAL SERVICE CERTIFICATE OF MAIunU DOES NOT NATIONAL MAILMAY BE USED FOR DOMESTIC AND , FOR INSURANCE-POSTMASTER Received From: One piece of ordinary mail addressed to ¢ d LU cc LO a- F Co i L=am Z OOJ(O d. ?ocn CD C ¢ =1_nE _ r?N a fh U¢ 4 H LJ z n C c O Y !` -/ 1 c ' G W O ON O 1( ? ? o ;o PS Form 3817, January 2001 DATED: ! 3D a 8 Jane Adams, Esquire 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff I--, e v? 1 11 L--- -- Date Ilgen v. Ilgen - Services Provided Time 7/22/08 Prepared and forwarded interrogatories to Bernard Ilgen .5 9/4/08 Prepared and filed Motion to Compel Discovery .5 9/5/08 Forwarded Motion to Compel Discovery .1 9/18/08 Forwarded copies of Order .1 10/8/08 Prepared and filed Affidavit of Service .1 10/9/08 Prepared for and attended hearing regarding Motion to Compel Discovery .8 10/18/08 Sent out copies of Order l 10/30/08 Prepared and filed Motion for Sanctions .5 11/6/09 Forwarded copy of Rule to Show cause, via certified mail. .1 12/5/08 Re-sent Rule to Show Cause, via regular mail. .1 12/30/08 Prepared and filed Motion to Make Rule Absolute .5 3.4 HOURS * $185.00/HOUR $629.00 EXHIBIT D TERI L. ILGEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 1914 Civil Term BERNARD A. ILGEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Jane Adams, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing MOTION, in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Bernard Alan Ilgen 933 S. Michael St. St. Mary's, Pa. 15857 DATED: 2' J Jane Adams, Esquire 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff C:,. r-? e. 'y t`,l i ,_,,j r f4m 0 S 2 /,-, TERI L. ILGEN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. BERNARD A. ILGEN, Defendant : NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this Wf* Day of , 200? , upon consideration of Plaintiff's Motion to Make the Rule to Show Cause Absolute, the following relief is granted: A. Wife's counsel is authorized, without a release from Husband, to directly obtain any information as requested in Wife's Interrogatories, from Husband's employer or from any other entity or person having such relevant information. B. Husband shall be required to pay attorney's fees to Wife in the amount of $629.00 within thirty (30) days of this Order. THE COURT: J. cc: /Jane Adams, Esquire ,---Bernard Ilgen, Defendant, pro se s ?S n?.e ?l1 140? ?:=l 6C, :9 WI 9- Nvr HE , TERI L. ILGEN, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA BERNARD A. ILGEN, Defendant NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE The undersigned State Constable, upon oath, deposes and says: I served Bernard A. Ilgen, of 933 S. Michael Road, St. Mary's, Pa. 15857 a copy of the hearing notice for June 10, 2009, the Affidavit of Separation, and the Counter- Affidavit and Notice of Intent to Request Entry of final Divorce Decree, as follows: Location Served: Date Served: Time Served: fAky 'e, "01 00 Person Documents Delivered to: l tic &1 Signed: onstable o akieski Sworn to and Subscribed before me this rJ day of I v`PL? J 6? Notary blic V/WA ORAW"Kw Go""'i091 luax*w. Pennsania Association of Notaries 2009. OF THE 2009 MAY 12 J?u: 51 Ci AIL' F 4 TERI L. ILGEN, Plaintiff BERNARD A. ILGEN, Defendant NOTICE OF FILING MASTER'S REPORT The report of the Master has been filed this dote and copies have been sent with this notice to counsel of record and the parties. In accordance with P.R.C.P. 1920.55 within ten'I(10) days after the mailing of this notice and report exceptions may be filed to the report by any party. If no exceptions are filed within the ten (10) day period, the Court shall recei e the report, and if approved, shall enter a final decree i accordance with the recommendations contained in the report. Date: 6/12/09 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 1914 CIVIL IN DIVORCE E. Robert Elick'er, II Divorce Masterl NOTE: If exceptions are filed, file the original with the Prothonotary and a copy with the Master's office. At that time, the party filing the exceptions should notify the court reporter in the Master's office so arrangements can be made for a transcript. Up n completion of the transcript and receipt of payment, the entire file will be returned to the Prothonotary's office for transmittal to the Court at time of argument on the exceptions. If no exceptions are filed, counsel shall prep re an order of Court consistent with the recommendations and provide a proposed order of Court to the M ster. Counsel shall also prepare and provide with th proposed order of Court a praecipe* to the Prothonotary directing the Prothonotary to submit the case to the Court for final disposition. The ]Master will then transfer the file with the proposed order of Court and praecipe to the Prothonotary's Office for docketing and transmittal by the Prothonotary to the Court. * III Form available in the Prothonotary's office an the Master's office. (NOT the praecipe to transmi the record form as set out in P.R.C.P. 1920.73(b).) F!Eu-DTIC' E CF THE F a'rION17MY 2009 JUH 12 ASS ID: 47 TERI L. ILGEN, Plaintiff, vs. BERNARD A. ILGEN, Defendant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, IN DIVORCE NO. 08-1914 CIVIL Filed on behalf of Defendant Filed by: Bernard A. Ilgen, Pro Se 933 South Michael Road St. Marys, PA 15857 Counsel for Plaintiff Jane Adams, Esquire 17 W. South Street Carlisle, PA 17013 TERI L. ILGEN, IN THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY, PENNSYLVANIA, vs. IN DIVORCE BERNARD A. ILGEN, ; Defendant, NO. 08-1914 CIVIL EXCEPTIONS AND NOW, to-wit, this 22°d day of June, 2009, comes Defendant, BERNARD A. ILGEN, and takes exception to the Master's Report of E. Robert Elicker, H, Divorce Master, as follows, to-wit:- 1. Defendant believes and therefore avers that the Master erred in notifying Defendant that he had 10 days within which to file exceptions, as Pa.R.C.P. No. 1920.55-2(b) affords parties 20 days in which to file such exceptions. 2. Defendant believes and therefore avers that the Master erred in allowing Defendant only 30 days within which to pay Plaintiff the sum of $120,000.00, as there is no possible way that Defendant can make application for a loan in such an amount, obtain approval for that loan, and close on that loan, within such a 30 day period. 3. Defendant believes and therefore avers that the Master erred in notifying Defendant to notify the court reporter in the Master's office that exceptions have been filed so that arrangements can be made for a transcript; according to the verifications which appear therein, a full and complete transcript of the hearing is attached to the :Master's Report as pages 1-14. 4. Defendant believes and therefore avers that the Master erred when including the property at 933 South Michael Road, Saint Marys. Pa. was abandoned by Teri L. Ilgen on September 2005. Bernard Ilgen was left with the financial burden and responsibility for this property. Teri Ilgen refused to pay any portion of real estate taxes, homeowners insurance, or maintenance costs on the property. A $14000.00 loan that was against the property in joint names, was also ignored by Teri Ilgen. The financial burden was beared solely by Bernard. Since the property is included in the divorce settlement, Bernard asks for reimbursement of these costs. 5. Defendant believes and therefore avers that the Master erred in allowing estimated property value for 933 South Michael, Saint Marys, Pa. of $180.000.00 Value of said property is over inflated and real value should be reassessed. A loan for this amount would not be attainable and exceeds market value in the Elk County area. 6. Defendant believes and therefore avers that the Master erred in allowing false statements made by Teri L. Ilgen, under oath, on June 10, 2009 hearing for Case No. 08- 1914. Defendant believes that this was done for Teri Ilgen's financial gain. Defendant asks that perjury charges be filed against Teri L. Parana, aka. Teri L. Ilgen, aka. Teri L. McNeal. 7. Defendant believes and therefore avers that the Master erred by allowing false claims, by Teri L. Parana, to a joint savings account that was spent by Teri Ilgen during separation. 8. Defendant believes and therefore avers that the financial statements, court filings by Jane Adams were taken or destroyed during multiple break-ins by Teri L. Ilgen. Reasons for these actions, by Teri Ilgen are unknown. Immediately after one break-in Att. Jane Adams requested these financial statements and records from Bernard Ilgen through a court filing in this case. 9. Defendant believes and therefore avers that Teri L. Ilgen did not make known to the court her financial assets. It was stated that Teri has no retirement. This is untrue. 10. Defendant believes and therefore avers that statements made that Teri L. Parana's signature was forged for the sale of 2000 Pontiac and 1998 Chevy are untrue. Both vehicles are in Bernard Ilgen's possession. A 2007 GMC Denali was not included. This vehicle was jointly owned at the time of separation and was in Teri Ilgen's possession. This statement about forgery of Teri L. Parana's signature was questioned by the Master, and was sworn to by Teri L. Parana. 11. Defendant requests that the issues listed be reviewed before judgment. The untrue statements, and actions by Teri 1. Hgen should have some consequence. 12. Defendant believes and therefore avers that the master erred. WHEREFORE, Defendant prays your Honorable Court review the Master's Report submitted by E. Robert Elicker, II, Divorce Master, in light of the above Exceptions and determine whether or not an error was made in said descision. RESPECTFULLY SUBMIT TED, BY:- ? ernazd A. Ilge D endant AFFIDAVIT OF SERVICE I, BERNARD A. ILGEN, Defendant herein, do hereby certify that I did, the RP- day of June, 2009, serve upon the following individual set forth below a true and correct copy of the foregoing Exceptions in the above captioned matter, by U.S. Ordinary Mail, postage prepaid, addressed as follows, to-wit:- Jane Adams, Esquire 17 W. South Street Carlisle, PA 17013 E. Robert Elicker, II 9 North Hanover Street Carlisle, PA 17103 Cumberland County Prothonotary's Office Cumberland County Courthouse One Courthouse Square Carlisle, PA 17103 Dated: D Bernard A. Ilgen, e ndant 17 r., L109 ?V'vl 2?, ill 3i: 08 TERI L. ILGEN, V. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA BERNARD A. ILGEN, Defendant NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE MOTION TO CONTINUE AND NOW COMES, the Plaintiff, Teri L. Ilgen, now known as Teri L. Parana, by and through her Attorney, Jane Adams, Esquire, and moves this Honorable Court as follows: 1. Plaintiff, Teri L. Parana, (hereinafter referred to as "Wife"), and Defendant, Bernard A. Ilgen, (hereinafter referred to as "Husband") were married on May 7, 2001. 2. The above-captioned action was initiated by Wife filing a Complaint in Divorce on March 26, 2008. 3. A Master's report was filed on June 12, 2009. 4. Defendant filed exceptions on June 22, 2009 to the Master's report. 5. This matter has been listed for argument on July 22, 2009. 6. Plaintiff's attorney is scheduled to be at a Perry County custody conciliation on that day and time. The issue in the custody case at hand pertains to a child's school district; therefore, it could be extremely prejudicial to that client if that case were continued and rescheduled after school starts. 7. There would be no foreseeable significant harm to the parties in this action if this matter is continued. 8. As of the date of filing of this action, Plaintiff has not received a copy of Defendant's brief, which was due. 9. This matter was previously assigned to Judge Guido. 10. It is not known whether or not Defendant would consent to the relief requested, as Defendant has refused to cooperate or appear in this matter, and actually hung up on Counsel the last time she attempted to call him. However, it is not believed that a continuance would not cause harm to his position. 11. Counsel consulted her own client and there were no objections to a continuance. WHEREFORE, Wife's Counsel respectfully moves this Honorable Court for a continuance of the July 22, 2009 argument date. Date:` 1161d ) By: &e Adams, Esquire 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 I.D. No. 79465 Attorney for Plaintiff TERI L. ILGEN, Plaintiff V. BERNARD A. ILGEN, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 1914 Civil Term : CIVIL ACTION - LAW :.IN DIVORCE CERTIFICATE OF SERVICE I, Jane Adams, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing MOTION, in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Bernard Alan Ilgen 933 S. Michael St. St. Mary's, Pa. 15857 DATED: Jane Adams, Esquire 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff Flia -in LLm?eR?C)Ln? COLL41-/ Pro}?xono?E ?Ljt? 10 ,q *7.U-0,? From: 07/13/2009 16:44 #026 P.002/002 TERI L. ILGEN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE V. BERNARD A. ILGEN, Defendant ORDER OF COURT AND NOW, this J s` Day of , 2009, upon consideration of Plaintiffs Motion for a Continuance, such Motion is granted. To reschedule this case, Defendant or Plaintiff's counsel may file a new praecipe to list this matter for argument. 7-4, Gpvvi hej ?a 41 ^41 Q J o? -yl t o%Et c' `?? OvsLr-? 4$4- dyk- cc: ane Adams, Esquire rnard 11gen, Defendant, pro se BY THE COURT- 2009 JU 15 PH 3; 5 ?.IUR? _, y:? 4+ e TERI L. ILGEN, Plaintiff V. BERNARD A. ILGEN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08 -1914 Civil Term : CIVIL ACTION - LAW : IN DIVORCE : Filed on behalf of Defendant : Bernard A. Ilgen, Pro Se EXCEPTIONS FOR ARGUMENT AND NOW, this 16th day of July 2009, comes Defendant, BERNARD A. ILGEN, and files exceptions for argument to the Master's Report of E. Robert Elicker,11, Divorce Master, as follows, to-wit:- 1. Defendant, Bernard A. Ilgen, and Plaintiff, Teri L. Ilgen, now known as Teri L. Parana, were married on May 7, 2001. 2. Plaintiff, Teri L. Ilgen, abandoned Defendant, Bernard A. Ilgen on or about September 1, 2005, leaving Defendant with all financial burdens. 3. Plaintiff and Defendant were residents of Elk County until Plaintiff, Teri L.11gen, abandoned the property at 933 S. Michael Road, Saint Marys, Pa. 4. Plaintiff, Teri L. Ilgen, filed an affidavit of separation, in Cumberland County Court, in the above captioned case on March 21, 2008, through her attorney, Jane Adams. 5. The Defendant's residence, 933 S. Michael Road, Saint Marys, Pa. was illegally entered during multiple break ins from April 2008 to August 2008, by the Plaintiff, Teri L. Parana. During these break ins, property was taken, property was destroyed, and legal and financial documents stolen or destroyed, causing more financial hardship to the Defendant. 6. On June 12, 2009, a Divorce Master's report was filed and contained false statements made by Plaintiff, Teri L. Ilgen and should be subjected to the penalties. 7. On June 22, 2009 the Defendant filed exceptions for argument. 8. An argument date of July 22, 2009, was set by Cumberland County Prothonotary Office. 9. Plaintiffs attorney, Jane Adams filed for a continuance on this matter. WHEREFORE, Defendant prays your Honorable Court review the above Exceptions for Argument. RESPECTFULLY SUBMITTED, BY: Bernard A. Ilgen, Defendant AFFIDAVIT OF SERVICE I, BERNARD A. ILGEN, Defendant herein, do hereby certify that I did, the day of July, 2009, serve upon the following individual set forth below, a true and correct copy of the foregoing in the above captioned matter, by U.S. Mail, postage prepaid,and addressed as follows, to-wit:- TERI L. PARANA, Plaintiff 8 HOPE TERRACE CARLISLE, PA. 17103 CUMBERLAND COUNTY PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA. 17013 Bernard A. Ilgen, Defendant rt r 11 TERI L. ILGEN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. BERNARD A. ILGEN No. 2008-1914 CIVIL TERM PRAECIPE FOR LISTING CASE FOR ARGUMENT TO THE PROTHONOTARY: List the within matter for the next Argument Court. 1. Matter to be argued: Defendant's Exceptions to Master's Recommendation. 2. Counsel who will argue cases: (a) Plaintiff: Jane Adams, Esquire 17 West South Street Carlisle, PA 17013 3 4. (b) Defendant: Bernard Ilgen 933 South Michael Road. St. Marys, PA 15857 I will notify all parties in writing within two days that this case has been listed for argument. Argument Court Date: Date: V September 9, 2009 J? Print name Attorney for :Plaintiff ek /4Z F;? FE)._; r tCE ARY 2009 ju 29 I a: 59 t ? .y TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BERNARD A. ILGEN, DEFENDANT 08-1914 CIVIL TERM IN RE: EXCEPTIONS OF DEFENDANT TO THE REPORT OF THE DIVORCE MASTER ORDER OF COURT AND NOW, this day of September, 2009, IT IS ORDERED: (1) Except for the marital residence at 933 South Michael Road, Saint Marys, Elk County, Pennsylvania, all marital property currently in the possession of either husband or wife is awarded to that spouse. (2) Husband shall pay wife $120,000, plus the sanction of $720, for a total of $120,720 within sixty days of this date. When this payment is made, wife shall transfer all her right, title and interest in 933 South Michael Road, Saint Marys, Elk County, Pennsylvania to husband. If the payment is not made but, within sixty days of this date, husband has a written financing commitment for the property, a copy of which he has provided wife, that will produce $120,720 to be paid to wife at settlement, the $120,720 shall be paid to wife at settlement at which time she shall transfer all her right, title and interest in the property to husband. (3) If the marital property is not transferred to husband pursuant to Paragraph 2, or upon the cancellation of any settlement under the second option in Paragraph 2, wife is granted a limited power of attorney to (1) list the marital property for sale with a reputable realtor at a price recommended by the realtor, (2) sell the property at a price agreed by her and the buyer, and transfer the property to the buyer by signing all necessary documents for 08-1914 CIVIL TERM herself and for husband as his power of attorney. Upon receipt of the net proceeds of sale, including the payment of a realtor's fee, wife shall receive $120,720. Any remaining proceeds shall be distributed to husband. (4) If wife lists the property for sale it shall be husband's duty to fully cooperate with the realtor for the proper presentation and showing of the property. If he does so he may live in the property until it is sold. If he fails in his duty wife may seek and obtain an order in this court requiring him to vacate the premises. (5) Wife shall have access to the marital residence and may not be prevented entry by husband. ,f By the Court, Edgar . Bayley, J. ane Adams, Esquire For Teri L. Ilgen Xernard A. Ilgen, Pro se 33 South Michael Road S 9 Saint Marys, PA 15857 ? E. Robert Elicker, II, Esquire Divorce Master Cyno:i\ box) :sal -2- ?i_wL-{ Iu 2094 S E P 28 FIN i2': 1, TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BERNARD A. ILGEN, DEFENDANT 08-1914 CIVIL TERM IN RE: EXCEPTIONS OF DEFENDANT TO THE REPORT OF THE DIVORCE MASTER MEMORANDUM OPINION AND ORDER OF COURT Bayley, J., September 28, 2009:-- Teri L. Ilgen and Bernard A. Ilgen were married on May 7, 2001. They separated in September, 2005. Husband still lives in the jointly owned marital residence at 933 South Michael Road, Saint Marys, Elk County, Pennsylvania. On June 21, 2008, the home was appraised at $180,000. There is no mortgage on the property. Wife sought equitable distribution of marital property. A hearing was held before the Cumberland County Divorce Master. Husband did not participate. The Master filed a Report recommending that the divorce be granted pursuant to 23 Pa.C.S. Section 3301(d) of the Divorce Code, along with recommendation for the equitable distribution of marital property. Husband filed exceptions to the proposed economic order. All of the exceptions were fact based. The issues were briefed and argued on September 9, 2009. Under Cumberland County Rule of Court 1028(c)(6), pertaining to argument court: "Issues raised, but not briefed, shall be deemed abandoned." The only issues briefed by defendant are: The Defendant's residence, 933 S. Michael Road, Saint Marys, Pa. was illegally entered during multiple break ins [sic] from April 2008 to August 2008, by the Plaintiff, Teri L. Parana. During these break ins [sic], property was taken, property was destroyed, and legal and financial documents stolen or destroyed, causing more financial hardship to the Defendant. 08-1914 CIVIL TERM On June 12, 2009, a Divorce Master's report was filed and contained false statements made by Plaintiff, Teri L. Ilgen and should be subjected to the penalties. There is no evidence in the record to support either exception. Accordingly, we will dismiss defendant's exceptions to the Divorce Master's Report. Concurrent with the entry of a decree in divorce, the following economic order is entered.' ORDER OF COURT AND NOW, this day of September, 2009, IT IS ORDERED: (1) Except for the marital residence at 933 South Michael Road, Saint Marys, Elk County, Pennsylvania, all marital property currently in the possession of either husband or wife is awarded to that spouse. (2) Husband shall pay wife $120,000, plus the sanction of $720, for a total of $120,720 within sixty days of this date. When this payment is made, wife shall transfer all her right, title and interest in 933 South Michael Road, Saint Marys, Elk County, Pennsylvania to husband. If the payment is not made but, within sixty days of this date, husband has a written financing commitment for the property, a copy of which he has provided wife, that will produce $120,720 to be paid to wife at settlement, the $120,720 shall be paid to wife at settlement at which time she shall transfer all her right, title and interest in the property to husband. (3) If the marital property is not transferred to husband pursuant to Paragraph 2, or upon the cancellation of any settlement under the second option in Paragraph 2, wife is granted a limited power of attorney to (1) list the marital property for sale with a reputable ' We will adjust the timeframe recommended by the Master with respect to the payment for or sale of the marital residence. -2- 08-1914 CIVIL TERM realtor at a price recommended by the realtor, (2) sell the property at a price agreed by her and the buyer, and transfer the property to the buyer by signing all necessary documents for herself and for husband as his power of attorney. Upon receipt of the net proceeds of sale, including the payment of a realtor's fee, wife shall receive $120,720. Any remaining proceeds shall be distributed to husband. (4) If wife lists the property for sale it shall be husband's duty to fully cooperate with the realtor for the proper presentation and showing of the property. If he does so he may live in the property until it is sold. If he fails in his duty wife may seek and obtain an order in this court requiring him to vacate the premises. (5) Wife shall have access to the marital residence and may not be prevented entry by husband. By the ourt, Q Edgar B. Bayley, J. Jane Adams, Esquire For Teri L. Ilgen Bernard A. Ilgen, Pro se 933 South Michael Road Saint Marys, PA 15857 E. Robert Elicker, II, Esquire Divorce Master :sal -3- TERI L. ILGEN, PLAINTIFF V. BERNARD A. ILGEN, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-1914 CIVIL TERM DIVORCE DECREE AND NOW, Z,66, it is ordered and decreed that TERI L. ILGEN , plaintiff, and BERNARD A. ILGEN , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the urt, Attest: J. &tJ744 Prothonotary O'?? - 'of &4-60P - ;, 4 ?9f WA-? ??? g? ela ' ?i r i TERI L. ILGEN, Plaintiff H10 ?k _t§ iV' IN THE COUZT OF COMMON PLEAS CUMBER LA '9OU;NTY5-,F NNSYLVANIA V. BERNARD A. ILGEN, Defendant NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE PETITION FOR SPECIAL RELIEF PURSUANT TO DECREE AND PRIOR COURT ORDER AND NOW COMES, the Plaintiff, Teri L. Ilgen, now known as Teri L. Parana, by and through her Attorney, Jane Adams, Esquire, and moves this Honorable Court as follows: 1. Plaintiff, Teri L. Parana, (hereinafter referred to as "Wife"), and Defendant, Bernard A. Ilgen, (hereinafter referred to as "Husband") were married on May 7, 2001. 2. The above-captioned action was initiated by Wife filing a Complaint in Divorce on March 26, 2008, which contained a claim for Equitable Distribution. 3. On September 28th, 2009, the Divorce Decree was entered along with an Order of Court regarding Equitable Distribution and the report of the Divorce Master. A copy of that Order is attached as Exhibit A. 4. The prior Order provides, that Husband must pay Wife the sum of $120,720.00 within sixty (60) days or Wife can list and sell the marital property, located at 933 South Michael Road, St. Mary's, Elk County, Pennsylvania, and retain said sum from the proceeds of sale of the home. 5. As of the date of filing this petition, Husband has not paid Wife the amount of $120,720.00 as directed in the Order. 6. As of the date of this filing, to Wife's knowledge, Husband does not have a written financing commitment for the property. 7. On or about November 23?d, 2009, Wife contacted a realtor, namely, Cathie Bauer, of Anderson & Kim Realty Services, Inc., which is located at 390 Brusselles St., St. Mary's Pa. 15857. 8. Wife signed a listing agreement and made arrangements to have the marital property sold. 9. The realtor is recommending that the home be listed at the sales price of $165,000.00 according to a local market analysis. 9. On or about November 25, 2009, the realtor sent Husband a packet of information regarding listing the marital home. 10. The realtor has attempted several times to contact Husband, to make arrangements to put a sign on the property, and to make arrangements to enter the property for showings. 11. Husband refuses to cooperate or return the realtor's calls. 12. On or about November 26, 2009, drove by the home on a public road, and Husband appeared to be moving items onto a flatbed trailer. 13. The realtor is unable to take any further steps to sell the property and properly list the home unless she can have guaranteed access to and show the property to prospective buyers. 14. Husband continues to be non-cooperative and stonewall Wife's attempt to move this matter forward, as he has done throughout the course of this matter. 15. Wife knows of no reasonable basis for Husband's delay in providing the requested information other than to delay the final settlement. 16. It is unknown whether Husband will damage the property or remove key appliances or hardware in an effort to thwart Wife's settlement; however, given Husband's past conduct, Wife is concerned that is a possibility. 17. Wife is requesting the following relief: (a) An Order providing her with sole and exclusive possession to the property located at 933 South Michael Road, St. Mary's, Elk County, Pennsylvania, and requiring Husband to vacate the premises immediately. (b) Compensation for her additional attorney's fees and any other relief this Court may find reasonable. 18. During the course of the divorce, this matter was previously assigned to Judge Guido. 19. Wife's counsel has had no communication from Defendant; Defendant previously hung up on counsel when she tried to call, therefore, it is assumed Defendant is not in agreement with the relief requested in this Motion. WHEREFORE, Wife respectfully moves this Honorable Court for the relief requested. Date: 46 a Adams, Esquire W. South St. 2arlisle, Pa. 17013 (717) 245-8508 I.D. No. 79465 Attorney for Plaintiff TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BERNARD A. ILGEN, DEFENDANT 08-1914 CIVIL TERM IN RE: EXCEPTIONS OF DEFENDANT TO THE REPORT OF THE DIVORCE MASTER ORDER OF COURT AND NOW, this day of September, 2009, IT IS ORDERED: (1) Except for the marital residence at 933 South Michael Road, Saint Marys, Elk County, Pennsylvania, all marital property currently in the possession of either husband or wife is awarded to that spouse. (2) Husband shall pay wife $120,000, plus the sanction of $720, for a total of $120,720 within sixty days of this date. When this payment is made, wife shall transfer all her right, title and interest in 933 South Michael Road, Saint Marys, Elk County, Pennsylvania to husband. If the payment is not made but, within sixty days of this date, husband has a written financing commitment for the property, a copy of which he has provided wife, that will produce $120,720 to be paid to wife at settlement, the $120,720 shall be paid to wife at settlement at which time she shall transfer all her right, title and interest in the property to husband. (3) If the marital property is not transferred to husband pursuant to Paragraph 2, or upon the cancellation of any settlement under the second option in Paragraph 2, wife is granted a limited power of attorney to (1) list the marital property for sale with a reputable realtor at a price recommended by the realtor, (2) sell the property at a price agreed by her and the buyer, and transfer the property to the buyer by signing all necessary documents for 08-1914 CIVIL TERM herself and for husband as his power of attorney. Upon receipt of the net proceeds of sale, including the payment of a realtor's fee, wife shall receive $120,720. Any remaining proceeds shall be distributed to husband. (4) If wife lists the property for sale it shall be husband's duty to fully cooperate with the realtor for the proper presentation and showing of the property. If he does so he may live in the property until it is sold. If he fails in his duty wife may seek and obtain an order in this court requiring him to vacate the premises. (5) Wife shall have access to the marital residence and may not be prevented entry by husband. By the Court, 11 t . i"', ( Jane Adams, Esquire For Teri L. Ilgen Bernard A. Ilgen, Pro se 933 South Michael Road Saint Marys, PA 15857 E. Robert Elicker, II, Esquire Divorce Master sal Edgar B. Bayley, J. o-2- TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. BERNARD A. ILGEN, DEFENDANT 08-1914 CIVIL TERM IN RE: EXCEPTIONS OF DEFENDANT TO THE REPORT OF THE DIVORCE MASTER MEMORANDUM OPINION AND ORDER OF COURT Bayley, J., September 28, 2009:-- Teri L. Ilgen and Bernard A. Ilgen were married on May 7, 2001. They separated in September, 2005. Husband still lives in the jointly owned marital residence at 933 South Michael Road, Saint Marys, Elk County, Pennsylvania. On June 21, 2008, the home was appraised at $180,000. There is no mortgage on the property. Wife sought equitable distribution of marital property. A hearing was held before the Cumberland County Divorce Master. Husband did not participate. The Master filed a Report recommending that the divorce be granted pursuant to 23 Pa.C.S. Section 3301(d) of the Divorce Code, along with recommendation for the equitable distribution of marital property. Husband filed exceptions to the proposed economic order. All of the exceptions were fact based. The issues were briefed and argued on September 9, 2009. Under Cumberland County Rule of Court 1028(c)(6), pertaining to argument court: "Issues raised, but not briefed, shall be deemed abandoned." The only issues briefed by defendant are: The Defendant's residence, 933 S. Michael Road, Saint Marys, Pa. was illegally entered during multiple break ins [sic] from April 2008 to August 2008, by the Plaintiff, Teri L. Parana. During these break ins [sic], property was taken, property was destroyed, and legal and financial documents stolen or destroyed, causing more financial hardship to the Defendant. 08-1914 CIVIL TERM On June 12, 2009, a Divorce Master's report was filed and contained false statements made by Plaintiff, Teri L. Ilgen and should be subjected to the penalties. There is no evidence in the record to support either exception. Accordingly, we will dismiss defendant's exceptions to the Divorce Master's Report. Concurrent with the entry of a decree in divorce, the following economic order is entered.' ORDER OF COURT AND NOW, this s day of September, 2009, IT IS ORDERED: (1) Except for the marital residence at 933 South Michael Road, Saint Marys, Elk County, Pennsylvania, all marital property currently in the possession of either husband or wife is awarded to that spouse. (2) Husband shall pay wife $120,000, plus the sanction of $720, for a total of $120,720 within sixty days of this date. When this payment is made, wife shall transfer all her right, title and interest in 933 South Michael Road, Saint Marys, Elk County, Pennsylvania to husband. If the payment is not made but, within sixty days of this date, husband has a written financing commitment for the property, a copy of which he has provided wife, that will produce $120,720 to be paid to wife at settlement, the $120,720 shall be paid to wife at settlement at which time she shall transfer all her right, title and interest in the property to husband. (3) If the marital property is not transferred to husband pursuant to Paragraph 2, or upon the cancellation of any settlement under the second option in Paragraph 2, wife is granted a limited power of attorney to (1) list the marital property for sale with a reputable 'We will adjust the timeframe recommended by the Master with respect to the payment for or sale of the marital residence. -2- 08-1914 CIVIL TERM realtor at a price recommended by the realtor, (2) sell the property at a price agreed by her and the buyer, and transfer the property to the buyer by signing all necessary documents for herself and for husband as his power of attorney. Upon receipt of the net proceeds of sale, including the payment of a realtor's fee, wife shall receive $120,720. Any remaining proceeds shall be distributed to husband. (4) If wife lists the property for sale it shall be husband's duty to fully cooperate with the realtor for the proper presentation and showing of the property. if he does so he may live in the property until it is sold. If he fails in his duty wife may seek and obtain an order in this court requiring him to vacate the premises. (5) Wife shall have access to the marital residence and may not be prevented entry by husband. By the Court, Edgar B. Bayley, J. Jane Adams, Esquire For Teri L. llgen Bernard A. Ilgen, Pro se 933 South Michael Road Saint Marys, PA 15857 E. Robert Elicker, II, Esquire Divorce Master :sal -3- VERIFICATION I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: I d- )A 00 1 &,U-, Y 11-? 4t't -- Teri L. Parana, f/k/a/ Teri L. Ilgen, Plaintiff TERI L. ILGEN, Plaintiff V. BERNARD A. ILGEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Jane Adams, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing PETITION in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Bernard Alan Ilgen 933 S. Michael St. St. Mary's, Pa. 15857 DATED: l d Jane Adams, Esquire 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff TERI L. ILGEN, Plaintiff V. BERNARD A. ILGEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 -1914 CIVIL TERM ORDER OF COURT AND NOW, this 7TH day of JANUARY, 2010, a hearing on Plaintiff s request to evict Defendant from the premises located at 933 South Michael Road, Saint Mary's Elk CounterPennsylvania, is scheduled for FRIDAY, FEBRUARY 5, 2010, at 3:00 p.m. in Courtroom # 3 of the Cumberland County Courthouse, Carlisle, Pa. ZJane Adams Bernard Ilgen sld ?n By e Court, Edward E. Guido, J. p !rS y z (f ?F i Z ry-133 cC% ? co rr, N TERI L. ILGEN, Plaintiff V. BERNARD A. ILGEN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08 - 1914 Civil Term CIVIL ACTION - LAW ?M IN DIVORCE Filed on behalf of Defendant Bernard A. Ilgen, Pro Se J_ c PETITION FOR DISMISSAL OF COURT ORDER DATED SEPTEMBER 28, 2009 FOR DEFENDANT'S NOW RECIEPT OF ORDER AND DISMISSAL FOR FRAUDULENT CLAIMS MADE BY PLAINTIFF TERI L. PARANA, AND A REQUEST FOR NEW HEARING AND NOW, this 9th day of January, 2010, comes Defendant, BERNARD A. ILGEN, and requests the dismissal of a Court Order of Divorce decree, dated September 28th, 2009, regarding distribution of property from Defendant to Plaintiff, and requests to move this Honorable Court as follows: 1. Defendant, Bernard A. Ilgen, and Plaintiff, Teri L. Ilgen, now known as Teri L. Parana, were married on May 7, 2001. 2. Plaintiff, Teri L. ilgen, abandoned Defendant, Bernard A. Ilgen on or about September 1, 2005, leaving Defendant with all financial burdens. 3. Plaintiff and Defendant were residents of Elk County from October 2003 to September 2005. Plaintiff, Teri L. Ilgen, abandoned the Elk County property at 933 S. Michael Road, Saint Marys, Pa. on September of 2005. 4. Plaintiff, Teri L. Ilgen, filed an affidavit of separation, in Cumberland County Court, in the above captioned case on March 21, 2008, through her attorney, Jane Adams. 5. The Defendant's residence, 933 S. Michael Road, Saint Marys, Pa. was maliciously and illegally entered during multiple break ins from April 2008 to August 2008, by the Plaintiff, Teri L. Parana. During the break ins, property was taken, property was destroyed, and legal and financial documents stolen or destroyed, causing more financial hardship to the Defendant. 6. On June 12, 2009, a Divorce Master's report was filed and contained false statements made by Plaintiff, Teri L. Ilgen. Fraudulent claims were made by Plaintiff, Teri Parana, for property and funds that do not exist. All owned property was not included in the settlement that was retained by Teri L. ligen. 7. On June 22, 2009 the Defendant filed exceptions for argument on the basis of FRAUD. 8. An argument date of July 22, 2009, was set by Cumberland County Prothonotary Office. 9. Plaintiffs attorney, Jane Adams filed for a continuance on this matter. On September 9, 2009, the case was argued and Plaintiff did not show for the hearing. 10. An Order was generated by this Court on or about September 2009. Defendant DID NOT receive a true copy of a Court Order dated September 28th, 2009 until after November 28 of 2009. This Court Order was unknown to Defendant, therefore Defendant did not have the legal right to appeal this Court Order. 11. Defendant received a copy from Plaintiffs counsel, Jane Adams, 63 days after the September 28th date. This was the only copy received. Defendant sent a response to Adams on December 1st, 2009, that there was no known order. Adams claims she has had no communication from Defendant, and continues to stonewall this Court to believe Defendant is not cooperating. 12. Property at 933 S. Michael Road, Saint Marys, Pa. is the sole residence of Defendant. There were no requests from Plaintiff to enter this property. Forceful break-ins were committed by Plaintiff. This property was extensively damaged by Plaintiff, Teri Parana, and her cohorts, after filing for divorce. Furniture and appliances were removed by Plaintiff during one of her break-ins. Defendant solely secured a loan for repairs and replacements. The property was valued at $180,000 on June 2008. Said property is now valued at $165,000. Claims made by Plaintiff, Teri Parana, and her counsel are untrue, and are meant to mislead this Court, and cause more financial damage to the Defendant. 13. Defendant is requesting the following relief: (a) Dismiss the September 28, 2009 Court Order for reason of fraud by Plaintiff, Teri Parana. (b) Dismiss the September 28, 2009 Court Order because of non receipt, and was unknown to Defendant. (c) Schedule a new hearing for equitable distribution by Pennsylvania law. (d) Provide compensation to Defendant for losses caused by Plaintiff. WHEREFORE, Defendant prays your Honorable Court review the above, and order the requested relief. RESPECTFULLY SUBMITTED, Date: BY: - Bernard A. Ilgen, ?1/endant TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1914 CIVIL TERM BERNARD A. ILGEN, Defendant CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 5th day of February, 2010, the Defendant is evicted and excluded from the residence at 933 Saint Michael Road, Saint Marys, Elk County, Pennsylvania. He must vacate said premises by February 21, 2010. If he does not, he may be forcibly evicted at any time on February 22, 2010, or thereafter. ? Jane Adams, Esquire For the Plaintiff n © _ Z _,I Bernard A. Ilgen zJC' -*i 933 Saint Michael Road Saint Marys, PA 15857 1 00 t4s? b Defendant, Pro se r = Sheriff =jr c . _ c:n .• srs L a/S f to By the Court, TERI L. ILGEN, Plaintiff V. BERNARD A. ILGEN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08 -1914 Civil Term : CIVIL ACTION - LAW (7 Q T? - : IN DIVORCE T) PQ _ : Filed on behalf of Defendant Fri : Bernard A. Ilgen, Pro Se ?- PETITION FOR TEMPORARY STAY OR DISMISSAL OF COURT ORDER DATED FEBRUARY 5, 2010 AND NOW, this 12th day of February, 2010 comes Defendant, BERNARD A. ILGEN, and requests the temporary stay or dismissal of a Court Order dated February 5, 2010, regarding Defendant's eviction and exclusion from property. Defendant requests to move this Honorable Court as follows: 1. Defendant, Bernard A. Ilgen, and Plaintiff, Teri L. Ilgen, now known as Teri L. Parana, were married on May 7, 2001. 2. Plaintiff, Teri L. Ilgen, abandoned Defendant, Bernard A. Ilgen on or about September 1, 2005, leaving Defendant with all financial burdens. 3. Plaintiff and Defendant were residents of Elk County from October 2003 to September 2005. Plaintiff, Teri L. Ilgen, abandoned the Elk County property at 933 S. Michael Road, Saint Marys, Pa. on September of 2005. 4. Plaintiff, Teri L. Ilgen, filed an affidavit of separation, in Cumberland County Court, in the above captioned case on March 21, 2008, through her attorney, Jane Adams. 5. The Defendant's residence, 933 S. Michael Road, Saint Marys, Pa. was maliciously and illegally entered during multiple break ins from April 2008 to August 2008, by the Plaintiff, Teri L. Parana. During the break ins, property was taken, property was destroyed, and legal and financial documents stolen or destroyed, causing more financial hardship to the Defendant. 6. On June 12, 2009, a Divorce Master's report was filed and contained false statements made by Plaintiff, Teri L. Ilgen. Fraudulent claims were made by Plaintiff, Teri Parana, for property and funds that do not exist. All owned property was not included in the settlement that was retained by Teri L. Ilgen. 7. On June 22, 2009 the Defendant filed exceptions for argument on the basis of FRAUD. 8. An argument date of July 22, 2009, was set by Cumberland County Prothonotary Office. 9. Plaintiffs attorney, Jane Adams filed for a continuance on this matter. On September 9, 2009, the case was argued and Plaintiff did not show for the hearing. 10. An Order was generated by this Court on or about September 2009. Defendant DID NOT receive a true copy of a Court Order dated September 28`h, 2009 until after November 28 of 2009. This Court Order was unknown to Defendant, therefore Defendant did not have the legal right to appeal this Court Order. 11. On or about January 9, 2010, Defendant filed a petition for dismissal of the September 28, 2010 Court Order based on fraudulent claims and false testimony by Plaintiff, Teri Parana. A new hearing was also requested by Defendant to prove false claims by the Plaintiff. This petition is currently pending. 12. The Court Order dated February 5, 2010, and signed by Judge Guido, does not allow Defendant enough time to find an alternative residence. Due to bad weather, amount of cash needed to move, and current work schedule, Defendant cannot secure another residence. JAN 292010 TERI L. ILGEN :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 08 -1914 CIVIL TERM BERNARD A. ILGEN : CIVIL ACTION - LAW Defendant : IN DIVORCE ORDER OF THE COURT AND NOW, this i 7 Day of 5 ,2010, upon consideration of Defendant's Petition, the CawaflvA off "eel Septembei 28,2669, sh e _nf this ;t,,4; 6N)- E , A new hear n chall beget f r 1Pquj4a1%1- Tl:..+,«1+»ti?„ ?o?•er?? j4' 3 Cc: Terri Z L. Parana Jane Adams CV - Try) c? ^a ' -r z + Cat --C G t FEB 2 32010?j 3 TERI L. ILGEN :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 -1914 CIVIL TERM BERNARD A. ILGEN : CIVIL ACTION - LAW Defendant : IN DIVORCE ORDER OF THE COURT AND NOW, this Day of ,20 10, upon consideration of Defendant's Petition, , Fiction 2010 t. Z Cc: Seri L. Parana /Jane Adams V.4 t0 T, - -? i ?T r1;T Cf 1 r o L; TERI L. ILGEN, V. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA, BERNARD A. ILGEN, Defendant NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE , 2010, the De nd,-jt ism ORDER OF COURT AND NOW, this Day of /0"44k evicted and excluded from the residence at 933 South Michael Road, St. Mary's, Elk County, Pennsylvania. Wife is granted sole and exclusive possession of said property, and if Husband does not voluntarily leave said property, he may be forcibly evicted. The Elk County Sheriff assist Wife with said eviction, upon her written request. Y TH 1-1 J. cc: ane Adams, Esquire ernard Ilgen, Defendant, self represented t TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. BERNARD A. ILGEN, Defendant NO. 2008 - 1914 CIVIL TERM CIVIL ACTION -LAW ORDER OF COURT AND NOW, this 23RD day of JULY, 2010, a hearing on Defendant's "Petition to Transfer Ownership of Vehicles" is scheduled for WEDNESDAY, AUGUST 4, 2010, at 4:00 n.m. in Courtroom # 3 of the Cumberland County Courthouse, Carlisle, Pa. Court, Edward E / Teri L. Parana ~rnard A. Ilgen ,mss. Robert Elicker, Esquire Court Administrator ' I ald c~« m~~~~ 7~a4 jiv J. AUp p 4 2010 , TERI L. ILGEN, V. Plaintiff BERNARD A. ILGEN, Defendant AND NOW, this IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 1914 Givil Term CIVIL ACTION -LAW IN DIVORCE ORDER OF COURT Day of ~lu 6u-.s~` 2010, this matter is consolidated with Husband's Petition regarding Transfer of Vehicles, and continued until the ~~ Day of ~ ~~~~~ , 2010, at ~• Ada ~./P.M. in Courtroom No. ~ of the Cumberland County Courthouse, Carlisle, Pennsylvania, 17013 at which time Wife's Petition for Contempt will also be heard. BY TH J. cc: Jane Adams, Esquire ~ `=~_; °'P'Y ~ ~~ ~~.. ~ Bernard Ilgen, Defendant, self-represented Q~ ~= -0 ~y ~p ~ es n1.c~.~heaf ~~4~~ d ~ -~ ~/~L- ~ , . ~~ q -~ _` {'-~ TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 08-1914 CIVIL TERM BERNARD A. ILGEN, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER OF COURT AND NOW, this 4th day of October, 2010, after hearing, Plaintiff is directed to sign the title transferring ownership of the 2000 Pontiac and 1998 Chevy truck to husband upon payment to her of $2,145.16. In all other respects, the petition of the Plaintiff and Defendant are DENIED. .iC7"ane Adams, Esquire For the Plaintiff ~rnard A. Ilgen Defendant, pro se ~~ Sheri f f .--~ ~~. ~ ~t.~:~4._Q ~,~,-~, srs ~o ~' der 0 \o ~.1 °~ o -,~ ., ~" ~~ f^~ ~ ~~ ~ ~~ n ~ #..... f "~ " .'".~ "'{ CJl ~ -4 3~ p ~ ~~ s,.+. ~ .::' O C"~'1 -^,~ Flq'L- 0- OF 1C!I- ,C ,r? i r 2311 FFB 23 FM 1: 2' TERI L. ILGEN, Plaintiff IN THE COURT OF COMMON PURINRLAND ii CUMBERLAND COUNTY, PENNS`F IE)MRI ANA A V. BERNARD A. ILGEN, Defendant NO. 08 - 1914 Civil Term CIVIL ACTION - LAW IN DIVORCE PETITION FOR CONTEMPT AND NOW COMES, the Plaintiff, Teri L. Ilgen, now known as Teri L. Parana, by and through her Attorney, Jane Adams, Esquire, and moves this Honorable Court as follows: 1. Plaintiff, Teri L. Parana, (hereinafter referred to as "Wife"), and Defendant, Bernard A. Ilgen, (hereinafter referred to as "Husband") were married on May 7, 2001. 2. On September 28th, 2009, the Divorce Decree was entered along with an Order of Court regarding Equitable Distribution and the report of the Divorce Master, under the above-captioned number. 3. Wife later petitioned for contempt of the prior Order issued in this matter. An Order of Court was issued on October 4, 2010, (a copy of which is attached), which directed Wife to sign the titles to the 2000 Pontiac and 1998 Chevy Truck upon Husband paying her $2145.66. 4. Husband has not contacted Wife or her counsel, has not offered to pay the amount directed, and has not forwarded the car titles. 5. Wife's counsel recently wrote Husband and requested he comply with the court Order. 6. Husband has not responded to Wife's counsel's request for cooperation in resolving this matter. 7. Wife is asking that Husband pay her the sum of $2145.16 and that she contemporaneously sign the car titles, as directed in the prior Order, or that he be found in contempt of the court Order. 8. Wife has incurred additional attorney's fees due to non-compliance with the court Order in this matter. 9. Wife's counsel wrote a letter to Defendant on January 27, 2011 requesting compliance; there has been no response, therefore, It is assumed that Husband does not agree with the relief requested. 10. This matter was previously heard by Judge Guido. 11. Wife is requesting the following relief: (a) That Husband be directed to bring the vehicle titles to the Hearing scheduled in this matter, so that they may be held in escrow by Wife's attorney. (b) That Husband be ordered to pay the amount of $2,145.16 as directed in the prior Order, within ten (10) days. (c)That Husband be found in contempt of the prior Order of October 4, 2010. (d) That Husband be responsible for paying Wife's reasonable Attorney's fees, which were incurred due to Husband's non-compliance with the prior Order. (e) Any other such relief as deemed appropriate. WHEREFORE, Wife respectfully moves this Honorable Court to set a hearing int his matter and grant her the relief requested. Date: a/aa/il J Adams, Esquire 7 South St. C rlisle, Pa. 17013 17) 245-8508 I.D. No. 79465 Attorney for Plaintiff TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1914 CIVIL TERM BERNARD A. ILGEN, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER OF COURT AND NOW, this 4th day of October, 2010, after hearing, Plaintiff is directed to sign the title transferring ownership of the 2000 Pontiac and 1998 Chevy truck to husband upon payment to her of $2,145.16. In all other respects, the petition of the Plaintiff and Defendant are DENIED. By the C Edward E. Guido, J. Jane Adams, Esquire "For the Plaintiff Bernard A. Ilgen Defendant, pro se Sherif f srs - ?X+n6,rfl-- VERIFICATION I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: Teri L. Parana, Plaintiff TERI L. ILGEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 1914 Civil Term BERNARD A. ILGEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Jane Adams, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing PETITION FOR CONTEMPT in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Bernard Alan Ilgen 340 Washington St. St. Mary's, Pa. 15857 DATED: of 3 Jane Adams, Esquire 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff 3 TERI L. ILGEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 1914 Civil Term BERNARD A. ILGEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE ORDER OF COURT AND NOW, this O>pay of /L/ , 2011, upon consideration of al heeavwery eand the Plaintiffs response: A hearing hereon is scheduled for the 3014 day of M A44 , 2011, at J/ 00 A.M./O%W Courtroom NoO3 of the Cumberland County Courthouse in Carlisle, Pennsylvania. BY J. cc: ?Jane Adams, Esquire Bernard Ilgen, Defendant, pro se r=}; u .> ev -Tj c co ?`? CD -1 TERI L. ILGEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V rte; . BERNARD A. ILGEN, ' M? : ; L U- M Defendant : NO. 2008 - 1914 CIVIL TERM , ?n 1 <Q -v o -+ =C:0 ORDER OF COURT co AND NOW, this 4TH day of APRIL, 2011, the Defendant having failed to appear for the hearing scheduled on the Petition for Contempt it is hereby ordered and directed as follows: 1.) Defendant shall pay Plaintiff the sum of $2145.16 within thirty (30) days of today's date. 2.) Said sum to be delivered to Plaintiff's attorney along with the titles to the 2000 Pontiac and 1998 Chevy truck. It shall be released to Plaintiff upon her execution of the titles transferring ownership of those vehicles to husband. If Defendant has not complied with the terms of this order he must appear before this court on THURSDAY, MAY 12, 2011, at 3:00 p.m. to show cause why he should not be held in contempt. Failure to appear shall result in the issuance of a bench warrant for his arrest. Jane Adams, Esquire For the Plaintiff Bernard Ilgen :sld 00po to it By,tlie-Court, Edward E. Guido, J. . 16 TERI L.I ILGEN, : IN THE COURT OF COMMON PLEASrQ Plaintiff : CUMBERLAND COUNTY, PENNSYL\8JAA ' r-- CA S V. : NO. 08 - 1914 Civil Term -?, BERNARD A. ILGEN, : CIVIL ACTION - LAW y' `•'•'' Defendant : IN DIVORCE AFFIDAVIT OF SERVICE The undersigned State Constable, upon oath, deposes and says: served BERNARD A. ILGEN, Defendant, a certified copy of the Order entered under t e above-captioned docket number on April 4, 2011, a copy of which is attache , as follows: Location Served F/T 3 4v Date;; d: ti Time Served: 1013itm Person Documents Delivered to: 8 e4f? i'L6-eW Signed: PA- r?t spa ?3+?o0 3?6 ) Sworn to and Subscribed before me this day of , 2011 Notary Public a TERRI L. ILGEN, Plaintiff V. BERNARD A. ILGEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ? r NO, 2008 - 1914 CIVIL TERM r ' C-) < s AC ` `-? ORDER OF COURT cy, ; ?- CO _.: AND NOW, this 4TH day of APRIL, 2011, the Defendant having failed to appear for jhe hearing scheduled on the Petition for Contempt it is hereby ordered and directed as follows: 1.) Defendant shall pay Plaintiff the sum of $2145.16 within thirty (30) days of today's date. Said sum to be delivered to Plaintiff's attorney along with the titles to the 2000 Pontiac and 1998 Chevy truck. It shall be released to Plaintiff upon her execution of the titles transferring ownership of those vehicles to husband. If Defendant has not complied with the terms of this order he must appear before this on THURSDAY, MAY 12, 2011, at 3:00 p.m. to show cause why he should not be held in contempt. Failure to appear shall result in the issuance of a bench warrant for his larrest. Jane Adams, Esquire Fo the Plaintiff Be and Ilgen :slc i ?I By?the?ourt,? „r s% Edward E. Guido, J. Cop VIIwI? (1?J TRUE COPY FROM RECORD In Testimony whereof, l here unto set my hand and the seal of said CqA at Carlisle. Pa. This day of , 20 ? ?r? rY