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HomeMy WebLinkAbout08-4730JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW MICHAEL E. FORD, : NO. 08- 47W CIVIL TERM Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree of divorce or annulment may be entered against you for any claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 or (800) 990-9108 JENNIFER L. FORD, Plaintiff V. MICHAEL E. FORD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. c? i- y'7 40 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Jennifer L. Ford, an adult individual currently residing at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Michael E. Ford, an adult individual currently residing at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 9, 1994, in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. COUNT II EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 13. Plaintiff and Defendant are joint owners of real estate located at 165 Valley Drive, Carlisle, Cumberland County, which was acquired during their marriage and which is subject to equitable distribution. 14. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. COUNT III ALIMONY ALIMONY PENDENTE LITE AND COUNSEL FEES AND EXPENSES 15. Paragraphs 1 through 14 are incorporated herein by reference as if set forth in their full text. 16. Plaintiff is unable to provide for, or afford her counsel fees, expenses and costs during the pendency of this divorce action, and through its resolution. 17. Plaintiff is without sufficient property and otherwise unable to financially support herself through appropriate employment. 18. Defendant is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses, and costs, as well as alimony, and alimony pendente lite for the Plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring Defendant to pay for Plaintiffs counsel fees, expenses, and costs as well as providing for payment of an appropriate alimony and alimony pendente lite to Plaintiff. Respectfully submitted, r . Griffie, Esquire torney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: JEI, IFE L. ORD -6" Su ? d Ll" Q? 7 L....P P?_., -a o tii JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW MICHAEL E. FORD, NO. (jt- q-736 CIVIL TERM Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Michael A. Scherer, acknowledge that on August o , 2008, I received a certified and true copy of a Complain in Divorce and Notice To Defend and Claim Rights on behalf of my client, Michael E. Ford, and confirm that I am authorized to do so. DATE 9' D ' ??k - MICHAEL A. SCHERER, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 C o O s' e-. . T3 C , 3s 31 m ? J' w C3 t; i TT1 C : N --i ;Kol . W JENNIFER L. FORD, Plaintiff V. MICHAEL E. FORD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 1736 CIVIL TERM IN DIVORCE PETITION FOR SPECIAL RELIEF IN THE FORM OF EXCLUSIVE POSSESSION OF THE MARITAL RESIDENCE AND NOW, comes Petitioner, Jennifer L. Ford, by and through her counsel, Bradley L. Griffie, Esquire and the Law Firm of Griffie & Associates, and petitions the Court as follows: 1. Your Petitioner is Jennifer L. Ford, the Plaintiff in the above captioned action and an adult individual currently residing at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania. 2. Your Respondent is Michael E. Ford, the Defendant in the above captioned action and an adult individual currently residing at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania. 3. The parties are the natural parents of two children, namely, Kacey E. Ford, born October 16, 1998 and Andrew M. Ford, born August 2, 2003. 4. Petitioner filed and served a Complaint in Divorce, in the instant action, wherein she made claims for Divorce based upon consent, equitable distribution, alimony, alimony pendente lite, counsel fees and expenses. 5. Respondent has been represented in these proceedings by Michael A. Scherer, Esquire, of O'Brien, Baric & Scherer, 19 West South Street, Carlisle, Pennsylvania. 6. Since January of 2008, when Respondent moved from the marital residence for approximately 1 (one) week, he has continued to verbalize his intention to move from the home at some point. 7. Respondent is extremely confrontational with Petitioner and Petitioner does everything in her power to avoid Respondent's efforts at confrontations. 8. Respondent has repeatedly attempted to create verbal confrontations in front of the parties' young children, including advising the children that he or the Petitioner will be calling the police, that the Petitioner will be trying to have the Respondent taken to jail by the police, and other completely inappropriate comments which have created concern for the children. 9. The more the Petitioner avoids Respondent's attempts at confrontation, the more he has resorted to other inappropriate conduct. 10. The Respondent recently advised Petitioner that he would be paying the two (2) mortgages on the parties' property, but would not be paying any other expenses. 11. The Respondent's income from his employment with Cumberland County is in excess of $4,848.00 per month, gross, along with additional income which he secures through side jobs of computer work for private individuals. 12. Petitioner's income is approximately $1,838.00 gross per month. 13. Despite the Respondent's income being approximately 2 '/2 times the Petitioner's, he has failed and refused to assist with the finances of the home beyond payment of the mortgages, which are approximately $1,300.00 per month, leaving Petitioner to pay for all utilities, groceries, automobile insurance, automobile payment, and related items, as well as Petitioner's minimal personal needs, and all items for the children such as medical needs, school materials, school lunches, clothing, extra curricular expenses and medical needs, automobile insurance, automobile payment, and related items, as well as Petitioner's minimal personal needs. 14. In May of 2008, while Respondent continued to indicate that he was moving from the residence, the parties transferred all utilities and similar expenses from Respondent's name to Petitioner's name such that those expenses are now billed to Petitioner. 15. In the recent months, since Respondent has refused to provide financial assistance to the home, other than paying the mortgages on the home and with Petitioner refusing to be confrontational with Respondent or respond to his confrontational conduct, Respondent has attempted to create problems for the Petitioner and the children as follows: t A. Respondent had turned on and turned down the air conditioning in the home and opened the windows when temperature is in the low 70 degree area, so as to create additional expense for the Petitioner. B. Respondent has turned the heat up in the home far beyond what has been the family's practice in the past, and opened the windows so that cold air blows into the home and creates additional expense for the Petitioner; C. Respondent has begun extensive use and abuse of electricity use in the home (eg: when Petitioner and children returned from church, it is common for most of the lights of the home to be on and multiple televisions to be on in the home while Respondent is the only individual there); D. Respondent has turned the lights on in the home while Petitioner and the children are attempting to sleep, such as the hall light to the bedrooms, which conduct has included confrontation with the parties' 5 year old son who has gotten out of bed to turn off the lights, only to have Respondent turn the lights back on. 16. Respondent refuses to assist in the care of the home where he continues to reside including refusal to assist in cleaning the home in any manner, refusing to even place dirty dishes into the dishwasher, and general refusal to assist in any manner relative to day to day care and the maintenance of the home. 17. Respondent, who has a degree in computer technology such that he knows how to intercept cell phone communications and otherwise record confidential communications of individuals, has used his computer laptop, which is owned by his employer, Cumberland County, to servile the Petitioner's use of her cell phone and has taken action to place a recording device in Petitioner's automobile so as to hear any conversations that may occur in the automobile personally or by telephone. 18. Respondent is involved with another woman who is employed by Cumberland County and is still married and residing with her husband which meretricious relationship is known to many individuals employed in the Cumberland County Courthouse and many individuals in the general public, and which has been introduced to the parties' 5 year old son. 19. Respondent has prior alcohol abuse problem and recently Petitioner has discovered that he is again drinking, returning home late at night after drinking, and hiding his drinking at home when he is to be providing care for the children. 20. Respondent has engaged in a course of conduct on the internet where he has been viewing pornographic sites, particularly referencing teenagers, which has created a great concern for Petitioner. 21. Respondent has made inappropriate comments in Petitioner's presence relative to young teenage girls that he has seen out in public. 22. Respondent has on occasion been sleeping in the parties' 10-year-old daughter's bed, which creates additional concern for Petitioner, particularly when Respondent indicates that this is acceptable conduct according to his mores. 23. On the evening of Tuesday, October 21, 2008, Respondent came home at the Petitioner's dinner hour as Petitioner and the children were sitting down to a homemade dinner made by Petitioner and offered the children to eat pizza that he had brought home with him. 24. Petitioner did not object and simply allowed the children to choose whether they wanted to eat the home cooked meal or pizza, which resulted in the five-year-old eating pizza and the 10-year-old staying with Petitioner and eating the home cooked meal. 25. When Respondent could not secure the desired confrontational response from Petitioner, he began taking additional action, such as, using the individual drink containers that Petitioner uses for the youngest child's school snacks so that they would not be available for the child to take to school, throwing an empty tea carton on the living room floor and suggesting that he would "pick it up when he felt like it", and otherwise taking any action that he could to try to create confrontation with Petitioner. 26. Ultimately, when Respondent was confronting Petitioner after an extended period of time, Petitioner threw water from a glass in Respondent's face, which caused Respondent to become physical with Petitioner, pushing her and aggressively coming toward her. 27. Petitioner swung at Respondent in defense of herself and hit Respondent. 28. Respondent left the home and called the police from a neighbor friend's home, which resulted in the police investigating the matter, but not initiating any criminal charges against anyone. 29. Respondent's immature and childish conduct is having an adverse impact upon the children and particularly on the parties' 10 year old daughter, who is evidencing the stress created by Respondent's actions and evidencing a more and more withdrawn personality. 30. The Respondent's conduct is having an adverse impact upon the children and threatens to destroy the upcoming holidays for the children if Respondent remains in the marital residence. 31. Respondent has the financial ability, and through friends or family the personal ability as he did in January, to secure housing elsewhere pending the resolution of this divorce action. 32. Petitioner does not have the ability to secure separate housing for her and the children pending the resolution of this divorce action, but has been preapproved for sufficient funding to refinance the mortgage on the home in her name alone. 33. Petitioner, without question, has been the primary caretaker for the children, being originally a stay at home Mom and working part time so as to provide for all of the children's needs. 34. Respondent was superficially involved with the children up until the marital discord arose earlier this year, after which he has taken upon himself to become involved with the children from the standpoint of being a playmate, doing things such as purchasing a Wii game system, while Respondent/Petitioner is trying to figure out how to pay for groceries, and playing the game system with the children. 35. The Respondent's overall conduct is having an extreme adverse emotional impact upon the children of the marriage. 36. A copy of this petition has been provide to Respondent's legal counsel, Michael A. Scherer, Esquire, with notification that it is being filed through the Court of Common Pleas of Cumberland County. 37. It is believed that Respondent does not concur with the requests being made herein. 38. No Judge has been involved previously in these proceedings, or with these parties. WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon Respondent to show cause, if any he has, as to why Petitioner should not be granted exclusive possession of the marital residence in this matter and, pending further proceedings, requests that the Court enter an Order providing her with exclusive possession. Respectfully submitted, L. ffie, Esquire ome or Petitioner 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE:_%Q? `o"?Ocr Mn? JE FER fRD JENNIFER L. FORD, Plaintiff V. MICHAEL E. FORD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. d ?''ql,36 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire hereby certify that I did, the ;day of October, cause a copy of Plaintiff's Petition for Special Relief In the Form of Exclusive Possession of the Marital Residence to be served upon the Defendant's counsel of record, Michael A. Scherer, Esquire, by serving him by facsimile and first class mail, postage prepaid, and certified mail, restricted delivery, at the following addresses: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 DATE: f J M 6 ? C'a N3 , . r} w JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL E. FORD, DEFENDANT 08-4730 CIVIL TERM ORDER OF COURT AND NOW, this day of October, 2008, a hearing on within petition for special relief shall commence at 8:45 a.m., Thursday, November 20, 2008, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, Edgar B. Bayley, J. /Bradley L. Griffie, Esquire For Plaintiff Michael Scherer, Esquire For Defendant sal CIT. I es /ol;t 3/GiB t cr, N JENNIFER L. FORD, Plaintiff V. : MICHAEL E. FORD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-4730 CIVIL TERM ORDER OF CO RT AND NOW, this 7V6-- day of , 2008, the hearing - i - scheduled on the petition for special relief filed is this matter for Thursday, November 20, 2008 at 8:45 a.m. is rescheduled to Thursday, November 20, 2008 at 10:00 a.m. in Courtroom No. 2 of the Cumberland County Courthouse, /Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 Bradley L. Griffie, Esquire Griffie & Associates 200 North Hanover Street Carlisle, Pennsylvania 17013 l..o s , rrt? c LL BY THE COURT, Edgar B. Bayley, J. c- t CA- ?l ?s U Q CL c C14 JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW MICHAEL E. FORD, NO. 08-4730 CIVIL TERM Defendant : IN DIVORCE EDGAR B. BAYLEY, JUDGE ORDER OF COURT AND NOW, this rZ• 0 day of 209-1, 2008, upon presentation and consideration of the within Stipulation, IT IS HEREBY ORDERED AND DIRECTED that exclusive possession of the residence located at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania, is granted to Plaintiff, Jennifer L. Ford, from this time forward. Defendant, Michael E. Ford, is excluded from the premises and shall not enter upon the premises for any purposes without further Order of Court or written Agreement of the parties, pending the finalization of the divorce proceedings in this matter. This Order is entered in full and final satisfaction of the matter raised in the Petition for Exclusive Possession filed by the Plaintiff in this case. BY THE COURT, Edgar B. Bayley, Judge Cc Bradley L. Griffie, Esquire Attorney for Plaintiff Michael A. Scherer, Esquire Attorney for Defendant L7,e-C-%t-eZ M?tLj -,, ,, &20 46$ ?1 ?a ?i .?.• .?.. {-? t: ? wc?ss-' ='" ?„ JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW MICHAEL E. FORD, NO. 08-4730 CIVIL TERM Defendant IN DIVORCE EDGAR B. BAYLEY, JUDGE STIPULATION AND NOW, the day and year hereinafter set forth, the parties stipulate and agree as follows: 1. The Plaintiff, Jennifer L. Ford, is residing at the parties' marital home located at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania. 2. At the time of execution of this Stipulation, Defendant, Michael E. Ford, has vacated the former marital residence at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff has filed a Petition for Exclusive Possession of the marital residence to which the Defendant now concurs. 4. Plaintiff has been advised by her legal counsel, Bradley L. Griffie, Esquire, and Defendant has been advised by his legal counsel, Michael A. Scherer, Esquire. 5. The parties are agreeable to the entry of an Order in the form attached providing Plaintiff with exclusive possession of the former marital residence at 165 Valley Drive, Carlisle, Pennsylvania, to the exclusion of Defendant and, further, wish to have the Order executed by the Court in full and final satisfaction of the matter pending before the Court on the Plaintiff's Petition for Exclusive Possession. M r IN WITNESS WHEREOF, the parties hereto have set forth their hand and seal the day and year hereinafter written. L' l l 1. riffie, Esquire D to J FORD Scherer, Esquire ate IC L E. FORD JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW PACSES CASE NO. 053110490 MICHAEL E. FORD, NO. 08-4730 CIVIL TERM n o -, Defendant IN DIVORCE EDGAR B. BAYLEY, JUDGE rr? +, PETITION FOR ALIMONY PENDENTE LITE, f f -, INTERIM COUNSEL FEES AND EXPENSES 'c'ar Zn AND NOW comes Petitioner, Jennifer L. Ford, by and through her counsel of record, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1. Your Petitioner is the above named Plaintiff, Jennifer L. Ford, an adult individual currently residing at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania. 2. Your Respondent is the above named Defendant, Michael E. Ford, an adult individual current residing at 739 Hamilton Court, Carlisle, PA 17013 and who represented in these proceedings by Michael A. Scherer, Esquire, of 19 West South Street, Carlisle, Cumberland County, Pennsylvania. 3. Petitioner's date of birth is February 24, 1972, and her Social Security number is 204-56-6517. 4. Respondent's date of birth is October 29, 1967, and his Social Security number is 210-52-4827. 5. The divorce action filed by Petitioner to the above docketed number in the Court of Common Pleas of Cumberland County requests a divorce based upon Section 3301(c) of the Divorce Code of 1980 as amended, as well as a claim for Alimony Pendente Lite, Counsel fees and expenses, for which all filing fees have been paid. 6. Petitioner has employed counsel and will incur certain costs and expenses in pursuit of the aforementioned divorce action, but is without sufficient assets or income to support herself, pay for attorney's fees, or pay for the costs and expenses associated with this action. 7. Respondent has sufficient income and earning capacity, as well as assets, to support the Petitioner or to assist in supporting Petitioner, and to pay alimony pendente lite to Petitioner, as well as assist in paying her counsel fees, costs and expenses. 8. Petitioner resides in the former marital residence, owned jointly by the parties, and Petition is in need of financial assistance to maintain the joint mortgages on the property. WHEREFORE, Petitioner requests your Honorable Court to enter an Order of Alimony Pendente Lite, Interim Counsel Fees, Costs, and Expenses in this matter. Respectfully Submitted, Griffie, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: I v? Je#fer L. rd JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW MICHAEL E. FORD, NO. 08-4730 CIVIL TERM Defendant IN DIVORCE EDGAR B. BAYLEY, JUDGE CERTIFICATE OF SERVICE I, Bradley L. Griffie, Esquire hereby certify that I did, the ?ffday of January, 2009, cause a copy of the within Petition for Alimony Pendente Lite, Interim Counsel Fees and Expenses to be served upon the Plaintiff, Michael E. Ford, by serving his attorney of record by first class mail, postage prepaid, at the following address: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 DATE: 11 d 4 fie, Esquire rF r Plaintiff E & & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 C o c -4 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JENNIFER L. FORD ) Docket Number 08-4730 CIVIL Plaintiff ) VS. ) PACSES Case Number 370110610 MICHAEL E. FORD ) Defendant ) Other State ID Number ORDER OF COURT You, JENNIFER L. FORD plaintiff/defendant of 165 VALLEY DR, CARLISLE, PA. 17013-8852-65 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the FEBRUARY 10, 2009 at 8: 3 OAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 -0 FORD v • FORD PACSES Case Number: 370110610 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: `r chv*-?' Date of Order: -U a JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. 1 Service Type M Worker ID 21302 t •a In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JENNIFER L. FORD ) Docket Number 08-4730 CIVIL Plaintiff ) VS. ) PACSES Case Number 370110610 MICHAEL E. FORD ) Defendant ) Other State ID Number ORDER OF COURT You, MICHAEL E. FORD plaintiff/defendant of 759 HAMILTON CT, CARLISLE, PA. 17013-1519-59 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the FEBRUARY 10, 2009 at 8: 3 OAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income Statement and the appropriate Expense Statement, if required, attached to this order, completed as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M Form CM-509 Rev. 1 Worker ID 21302 FORD V. FORD PACSES Case Number: 370110610 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest and/or enter an interim support order. If paternity is an issue, the court shall enter an order establishing paternity. THE APPROPRIATE COURT OFFICER MAY ENTER AN ORDER AGAINST EITHER PARTY BASED UPON THE EVIDENCE PRESENTED WITHOUT REGARD TO WHICH PARTY INITIATED THE SUPPORT ACTION. BY THE COURT: Date of Order: 0 / -')-0 - 0 I JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE-HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-622-9 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Rev. 1 Service Type M Worker ID 21302 ? `? :3 ti ?. { ? ? ? ('J ? w""r 11 L,lr (,M,T t- - ' r r7 ? +? ^'? j,,, ( JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. DOMESTIC RELATIONS SECTION MICHAEL E. FORD, PACSES NO. 053110490 Defendant DOCKET NO. 1043 SUPPORT 2008 JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. DOMESTIC RELATIONS SECTION MICHAEL E. FORD, PACSES NO. 370110610 Defendant/Respondent DOCKET NO. 08-4730 CIVIL ORDER OF COURT AND NOW, this 11th day of February, 2009, this matter having been scheduled for a hearing de novo before the Support Master on the Plaintiff's complaint for spousal and child support and claim for alimony pendente lite, and the parties having reached an agreement on all outstanding parties, upon recommendation of the Master it is ordered and decreed as follows: 1. The Plaintiffs claim for spousal support is dismissed. 2. The Plaintiffs claim for alimony pendente lite is dismissed. 3. The interim order entered December 17, 2008 is affirmed as a final order. (,Tc,u , N GL Edgar B. Bayley, J. Cc: Jennifer L. Ford Michael E. Ford Bradley L. Griffie, Esquire For the Plaintiff Michael A. Scherer, Esquire For the Defendant DRO C7 o C7 co ' J 1 1 JENNIFER L. FORD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW PACSES CASE NO. 053110490 MICHAEL E. FORD, NO. 08-4730 CIVIL TERM Defendant IN DIVORCE EDGAR B. BAYLEY, JUDGE AND NOW comes Petitioner, Jennifer L. Ford, by and through her counsel of record, Bradley L. Griffie,!Esquire, and petitions the Court as follows: 1. Your Petitioner is the above named Plaintiff, Jennifer L. Ford, an adult individual currently residing at 165 Valley Drive, Carlisle, Cumberland County, Pennsylvania. 2. Your Respondent is the above named Defendant, Michael E. Ford, an adult individual current residing at 739 Hamilton Court, Carlisle, PA 17013 and who represented in these proceedings by Michael A. Scherer, Esquire, 'of 19 West South Street, Carlisle, Cumberland County, Pennsylvania. 3. Petitioneris date of birth is February 24, 1972, and her Social Security number is 204-56-6517. 4. Responddnt's date of birth is October 29, 1967, and his Social Security number is 210-52-4827. 5. The divorce action filed by Petitioner to the above docketed number in the Court of (Common Pleas of Cumberland County requests a divorce based A upon Section) 3301(c) of the Divorce Code of 1980 as amended, as well as a claim for Alimony Pendente Lite, Counsel fees and expenses, for which all filing fees have been paid. 6. Petitioner has employed counsel and will incur certain costs and expenses in pursuit of the aforementioned divorce action, but is without sufficient assets or income to support herself, pay for attorney's fees, or pay for the costs and exlpenses associated with this action. 7. Respondent I has sufficient income and earning capacity, as well as assets, to support the Petitioner or to assist in supporting Petitioner, and to pay alimony peodente lite to Petitioner, as well as assist in paying her counsel fees, costs and expenses. 8. Petitioner resides in the former marital residence, owned jointly by the parties, and Petition is in need of financial assistance to maintain the joint mortgages on the property. WHEREFORE, Petitioner requests your Honorable Court to enter an Order of Alimony Pendente Lite, Iterim Counsel Fees, Costs, and Expenses in this matter. Respectfully Submitted, Vo ?ffie, Esquire r for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements, herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to urlsworn falsifications to authorities. DATE: ! R L. F OW, Plaintiff JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW MICHAEL E. FORD, NO. 08-4730 CIVIL TERM Defendant IN DIVORCE EDGAR B. BAYLEY, JUDGE CERTIFICATE OF SERVICE jl? I, Bradley L. Griffi',e, Esquire hereby certify that I did, the b day of March, 2009, cause a copy of the',within Petition for Alimony Pendente Lite, Interim Counsel Fees and Expenses to be served upon the Plaintiff, Michael E. Ford, by serving his attorney of record by first class mail, postage prepaid, at the following address: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 DATE: I t .--' e riffle, wire tt ey for Plai fj GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 b C_ ?' - ,,;r, ? ?: ? ? # ' -a, ?.? ? :? -- , .. (?,1 ?( ? ???t .. ?g ? T?7 ? 7 " ?"; . °, ?.? ".°j JENNIFER L. FORD, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-4730 CIVIL TERM MICHAEL E. FORD, IN DIVORCE Defendant/Respondent : PACSES NO: 370110610 ORDER OF COURT AND NOW, this 18th day of March 2009, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R. J. Shadday on April 7. 2009 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.1 IC (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you. If you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. Copies mailed to: Petitioner Respondent Bradley L. Griffie, Esq. Michael A. Scherer, Esq. Date of Order: March 18, 2009 BY THE COURT, Edgar B. Bayley, President Judge 4dayJS/ I* , PL oordinator r YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 C'? rv t_`.? ° tic, . ? ?? ?? ?:r .ate ' ;,,, c': ?' - ?7 tip:` :? -? ?' JENNIFER L. FORD, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL E. FORD, Defendant : CIVIL ACTION - LAW NO. 08-4730 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 2. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 6, 2008, and served on August 8, 2008, as indicated in Acceptance of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: -?- 7--- Michael E. Ford, Defendant FILEtA..;1=t OF THE ' -;1.7?,NPTARY 20g9 MAY -! Ph I : 4 Z Try JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MICHAEL E. FORD, NO. 08-4730 CIVIL TERM Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: Gy "& - Michael E. Ford, Defendant Flt ED- r=„r 0r ?E a .' ^ GARY 2009 MAY -I Psi 1: 4 JENNIFER L. FORD, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-4730 CIVIL TERM MICHAEL E. FORD, IN DIVORCE Defendant/Respondent PACSES CASE: 370110610 ORDER OF COURT AND NOW to wit, this 11th day of May, 2009, it is hereby Ordered that the Petition for Alimony Pendente Lite, filed March 16, 2009 in the above captioned matter, is dismissed due to the Petitioner withdrawing her request for Alimony Pendente Lite pursuant to the parties' Marital Settlement Agreement. This Order shall become final twenty (20) days after the mailing of the notice of the entry of the order to the parties unless either party files a written demand with the Domestic Relations Section for a hearing de novo before the Court. BY THE COURT: Edgar B. ;ayley, J. DRO: R.J. Shadday xc: Petitioner Respondent Bradley L. Griffie, Esq. Michael A. Scherer, Esq. Form OE-001 Service Type: M Worker: 21005 Fi1.FrFICE OF 1W fqo-'NCB ?'1 2009 KAY t i pM 3'- 05 p&jr S, ?V; J1IA;?Y JENNIFER L. FORD V. MICHAEL E. FORD DIVORCE DECREE AND NOW, E Z--- _, it is ordered and decreed that JENNIFER L. FORD , plaintiff, and MICHAEL E. FORD , 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.") 0OULP, The parties' Separation and Property Settlement Agreement, dated April 2, 2009, is incorporated herein, but not merged. By the Court, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4730 Attest: J. K4 (- ?, 4- #?* Prothonotary 64. w. JENNIFER L. FORD, Plaintiff V. MICHAEL E. FORD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-4730 CIVIL TERM PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCE To the Prothonotary: Please withdrawal my appearance on behalf of Michael Ford in the above captioned matter. Date: October 21, 2009 Mic el A. Sch rer, Esquire 19 West South Street Carlisle, PA 17013 (717) 249-6873 Please enter by appearance on behalf of Michael Ford in the above captioned matter. Date: October 21, 2009 Michael E. Ford, Pro e 759 Hamilton Court Carlisle, PA 17013 FILE"YFICF OF "E PROTHONOTARY 2009 OCT 28 AM 10: 52 CUmCj3,,** «.. ":r`:?NTY FrENINi YLVARA