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Home My WebLink About04-0843 II MICHAEL R, ENT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW NO, Dq-~4)C~ KIMBERLEE A, ENT, 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 foregoing pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court, A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff, You may lose money or property or other rights important to you, including custody or visitation of your children, When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 1 II 'I MICHAEL R, ENT, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs, ) CIVIL ACTION - LAW ) NO, o'f. 'il./::J ) KIMBERLEE A, ENT, ) Defendant ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN.NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court, A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania, You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list, All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse, If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice, Failure to do so will constitute a waiver of your right to request counseling, 2 _.~....._~~ .,._,-_.,'........- .....-.......-,,-.- II MICHAEL R, ENT, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs, ) CIVIL ACTION - LAW ) ) NO,Otj - g'lJ KIMBERLEE A, ENT, ) Defendant ) IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, MICHAEL R, ENT, by his attorney, Samuel L, Andes, and makes the fol/owing Complaint in Divorce: 1, The Plaintiff is MICHAEL R, ENT, an adult individual who currently resides at 5276 Deerfield Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 2, The Defendant is KIMBERLEE A, ENT, an adult individual who currently resides at 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4, The Plaintiff and Defendant were married on 2 August 1980, 5, There have been no prior actions of divorce or annulment between the parties, 6, This marriage is irretrievably broken, 7, Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling, 3 II 8, The Plaintiff requests this Court to enter a Decree of Divorce, WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania, Sam , Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 I verify that the statements made in this Complaint are true and correct, I understand that any false statements in this Complaint are subject to the penalties of 18 Pa, C,S, 4904 (unsworn falsification to authorities), DATE: 2.- - /t -0 '-f 41/h- MICHAEL R, ENT 4 R\ \ 'J, -... ~ 05')' () b' ~ ~ ..... ('., +: .s, c/! + ---- --D (" "'r\... ~~. ~ p:- ~ -, LA r-- C/\ 0' (J. '-- r-' c"" (::. ~ r--..) <;'.~_':J C:'"_} (j -"I -...t "-r-. -" -.J - C:". --) f'-..'> (.) --' Plaintiff ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL R, ENT, vs, CIVIL ACTION. LAW KIMBERLEE A, ENT, Defendant NO, 04-843 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE The undersigned, Kimberlee A, Ent, does hereby accept service of the Divorce Complaint filed against her in this matter and acknowledges receipt of a certified copy of that Complaint, DATED: q;? tJr. tJ~ " / ~~~~~Gc:: KI EE A, ENT Q ( ~ -. ::.4 0 -~. CF'. r--.> = <..:::-:. C) .. :3: ::;:! h.i::'~! r--~ -0[2..: -'11..-' ~;; ~:) f'o' N ':-? .--,.. l~~ f~~; WILLIAM C. CRAMER ATTORNEY AT LAW CHAMBERSBURG. PA17201 (717) 264-3711 " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA INDEPENDENT AUTO PARTS, INC., Plaintiff CIVIL ACTION - LAW VS. NO, 2003-843 CIVIL TERM STAGECOACH TRANSPORT SERVICES, INC., STAGECOACH SALES & LEASING and HARRY PAPPAS, Defendants IN ASSUMPSIT MOTION FOR LEAVE OF COURT TO WITHDRAW AS COUNSEL FOR DEFENDANTS NOW COMES counsel for Defendants in the above captioned action and files this Motion stating as follows: FIRST The undersigned counsel filed an Answer for and entered his appearance on behalf of all three named Defendants in the above captioned matter. SECOND The above captioned case is now scheduled for arbitration trial, to commence at 10:00 a.m. on April 7, 2004. THIRD Counsel for Defendants is requesting leave of Court to withdraw as counsel because: WILLIAM C. CRAMER ATTORNEY AT LAW CHAMBERSBURG, PA 17201 (7171 264-3711 Ii A, The individual Defendant, namely, Harry Pappas, who is also the principal owner and CEO of the two corporate Defendants, has refused to return counsel's telephone calls or otherwise cooperate with counsel in the preparation of a defense. B. Irreconcilable differences exist between Defendants and the undersigned counsel with respect to matters involving the defense or other resolution of the case, FOURTH Plaintiff's counsel has been contacted regarding this matter and does not oppose Defendants' counsel withdrawing from the case, providing that trial of the case is not delayed. Plaintiff's counsel was served a copy of this Motion by facsimile transmittal on March 31, 2004 and also, by first class mail, postage prepaid, FIFTH Defendants have been notified of the filing of this Motion by overnight Federal Express delivery on March 31,2004 at Mr, Pappas' last known address of 5798 West Shore Drive, New Port Richey, Florida 34652 and also by facsimile transmittal, faxed to telephone number (727) 849-8099, on the same date, WHEREFORE, it is respectfully requested that the Court enter an Order permitting counsel to withdraw as counsel for the three named Defendants in the above captioned matter, Date: ,"1/311 tJJj ( Re,peo~J~k___ WilliK, C, Cramer Attorney for Defendants 14 North Main Street, Ste, 414 Chambersburg, PA 17201 (717) 264-3711 2 WILLIAM C. CRAMER ATTORNEY AT LAW CHAMBERSBURG, PA 17201 (717) 264-3711 CERTIFICATE OF SERVICE I, William C. Cramer, Attorney for Defendants, hereby certify that on this date I delivered a true and correct copy of the attached Motion for Leave of Court to Withdraw as Counsel for Defendants by first class mail, postage prepaid, and by facsimile transmittal upon Harold S, Irwin, III, Esq" Attorney for Plaintiff, 64 South Pitt Street, Carlisle, PA 17013, Fax No, (717) 243-9200, I also certify that on this date I delivered a true and correct of the attached Motion for Leave of Court to Withdraw as Counsel for Defendants by Federal Express overnight delivery and by facsimile transmittal upon Harry Pappas, 5798 West Shore Drive, New Port Richey, FL 34652, Fax No, (727) 849- 8099. Date: March 31, 2004 i I I I I i I, ! ! 3 ~,.::-': ~~.. , ;: {~'_: .J.....' s;; " --1 -<. Q ?2; r-'> C:;::l co;> .-:- 7~ -.J :;'J "'" :J';: r:~ "-' C) ~n ::;J .-I..-n r-nr,-,:. :9.,H .-~-' " ~~~) _"'t'~ " ~'~~ ~ ':~ (-:;ll'"! .:-! :j~ ~< II MICHAEL R, ENT, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs, ) CIVIL ACTION - LAW ) ) NO, 04-843 CIVIL TERM KIMBERLEE A, ENT, ) Defendant ) IN DIVORCE AFFIDAVIT OF CONSEI\/T 1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 26 February 2004 and was served upon the Defendant on or about 2 March 2004, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant, 3, I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree, 4, I have been advised of the availability of marria~le counseling and understand that he Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming inal. I verify that the statements made in this Affidavit are true and correct and I nderstand that false statements herein are made subject to the penalties of 18 Pa, C,S, ection 4904 relating to unsworn falsification to authoritills, 6 -~-c200'1 ATE #4Y;(?~ MICHAEL R, ENT (') ~ ~~:~ IT:; ..,:':'-,.;:.:" /-.::[~ OJ, .. 2L) ~- ;.:...., .,-( , Pc;:'; ,,~ =< '" = <=> ",- c... c:: ;;>= ~ ~::D ~r-~ -0 b ~=< x:tl 00 zen o ~ 52 -< U1 "'" :x C> CT> II MICHAEL R, ENT, Plaintiff IN THE COURT OF COMMON PLIEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW KIMBERLEE A, ENT, Defendant NO, 04-843 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301lcl OF THE DIVORCE CODE 1, I consent to the entry of a final decree in divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I verify that the statements made in this Affidavit are true and correct, I understand hat false statements herein are made subject to the penalties of 18 Pa, C,S, Section 4904 elating to unsworn falsification to authorities, b Jl ~ZOtJ'f ~( ;{J ~ MICHAEL R, ENT ated: 0 .... 0 = c: = .." ...- ~ ::r." ll~ ff~ <:- c:: /Tl- --,,, .- d_ -om :.:<: ,- :tJ6 (j), Ul 0 r':' .:;:!-ri :::> :P> ..;--1'1 3: f.)- :~ C) -~~ :.5 '<~r :2 ~ =2 C> ~b en -< II I , MICHAEL R, ENT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW KIMBERLEE A, ENT, Defendant NO, 04-843 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSErn 1, A Complaint in Divorce under Section 3301 (c} of the Divorce Code was filed on 26 February 2004 and was served upon the Defendant 011 or about 2 March 2004, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant, 3, I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree, 4, I have been advised of the availability of marriane counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and 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 ~~~ ~!I" ENT ----- o -,~ '+~r-::': -;" -," :2':C ~~p 5~~~, ~I~ '-,r ::3 -, ..., = "'" ... '- c:: ::z.: ~ ~-n f1'F -um S6 ;==+i ~~o f)rn :;:1 ~D --< c.n <:: ->- o en II MICHAEL R, ENT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW KIMBERLEE A. ENT, Defendant NO, 04-843 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TOJil;_QUEST ENTR'( OF A DIVORCE DECREE UNDER SECTION 3301lcl OF THE DIVORCE CODE 1, I consent to the entry of a final decree in divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, awyer's fees, or expenses if I do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the ourt and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I verify that the statements made in this Affidavit are true and correct, I understand hat false statements herein are made subject to the penalties of 18 Pa, C,S, Section 4904 elating to unsworn falsification to authorities, __~t -() b-tJ cI ated: "'4-- a/~~~ ~~, ENT C) c- ;,;: ;:gr:}': ~:1,1 ~t!_~ ~' r"l~ <' ;;:(-', ~~;~ ;?: ::;! ,.." ail ..... <- c:: z Sfl ~- rn.;..W ~~ :;:lSf> '",-d S:;?- ",,~_o Om ,.......! ;;:; :< Ul :l> ::;;r. <::) 010 II MICHAEL R. ENT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW KIMBERLEE A, ENT, Defendant NIO, 04-843 CIY'L TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section 3301 (c), 2, Date and manner of service of the Complaint: Personal service on 2 March 2004 (Acceotance of Service filed on 22 March 20041. 3, Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: by Plaintiff: 9 June 2004 by Defendant: 6 June 2004 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce (2) Date of filing and service of the Plaintiff's Affidavit upon the Code: Respondent: 4. Related claims pending: None 5, Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 9 June 2004, filed contemooraneouslv herewith, Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: dated 6 June 2004. filed contemooraneouslv herewith, Date:lS 0;'l<7e 2uJt:.\ By ~ r;J\\ a ~~~ Attorney for Plaintiff ~'~T 6J:. r..:c', ~F~ J=:r-c:.: ~ (') c: 2'" ...., g ..,... <- c:: :z: ~ -I :t:.." rn-:;:: -oe:J :PO I -0 -~J"'i :L-fl 00 2m o "'-1 ";.. "n ~ U1 ;po ::s: o en . . .. . . .. :+::+::+::+: :+: :+::+::+::f. :+: :of. :f.'f.:+: :+::+: :+::+::+: ;+; :+::+::+::+; ;Ii"" . . . . . . IN THE COURT OF COMMON PLEAS . OFCUMBERLANDCOUNTY . STATE OF PENNA, . . . MICHAEL R. ENT, No, 04-843 CIVIL TERM . Plaintiff . VERSUS . KIMBERLEE A. ENT, . Defendant . . . . . . DECREE IN DIVORCE . . AND NOW, ~ \OWL- z,\ 2004, IT IS ORDERED AND . . . . DECREED THAT MICHAEL R. ENT , PLAINTIFF, . . AND KIMBERLEE A. ENT , DEFENDANT, . . ARE DIVORCED FROM THE BONDS OF MATRIMONY, . . . . . . . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . . . . . . . . . . . . NONE . . . . . . . . . . . By T Amso~~ . ( - PRO~HONOTARY .. ;+; ;+;:+: :f.:+::f.'+':f:f. :f.:+::+::+::+:,+::+::f.:+::+: Of:+: :+::+: . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J, . . . . . . . . . . . . . . . . . . .' ,~~~.,~ ~ r ~/,?}',vw,~-,r?l ~ .. . . --. << ~., . ..; '~'. * At? .h r: '? htl....j,("',n . , . - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION STERLING, INC. CBA KA Y JEWELERS Plaintiff No, 05-843 CIVIL TERM vs, PRAECIPE TO SETTLE, DISCONTINUE & END WITH PREJUDICE BRYAN M, SIBBACH AND HOPE SIBBACH Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THlS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#0393908! ---- . ,,'" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION STERLING. INC, CBA KA Y JEWELERS Plaintiff vs, Civil Action No. 05-843 CIVIL TERM BRYAN M, SlBBACH AND HOPE SIBBACH Defendants PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter with Prejudice upon the records of the Court and mark the cost paid. .----' , \ _~P' "-,, ]to trr, . "\" \. r '" ,~~~7 '''''' of- \ 'c''''''''. I ., ':",,"" ,- ,...... Sworn to and subsfribed Before me the \. 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