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Home My WebLink About04-1574 TERRI BLUMENTHAL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : DIVORCE MICHAEL BLUMENTHAL, Defendant o ~- ,S1</ : No. CIVIL TERM 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 UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on June 1,2001, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 1 verity that the statements made in this affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. i-VtA-,\S k v>v h hD erri Blumenthal '~ 4,0].04- Date TERRI BLUMENTHAL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : DIVORCE Ot../-/:J1l/ : No. CIVIL TERM MICHAEL BLUMENTHAL, Defendant COMPLAINT FOR DIVORCE AND EOUlTABLE DISTRIBUTION The Plaintiff, Terri Blumenthal, by and through her attorneys, the Family Law Clinic, sets forth the following cause of action: COUNT I DIVORCE UNDER 23 Par C. S. SECTION 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is Terri Blumenthal, an individual residing at 151 West South Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Michael Blumenthal, an individual residing at 315 Pitt Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant are husband and wife, having been married on March 31, 1990. 4. Plaintiff and Defendant have lived separate and apart since June 1,2001. 5. Plaintiff has been a bona fide resident of Cumberland County and this Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 6. There have been no prior actions of divorce or annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. WHEREFORE, Plaintiff respectfully requests the Court to enter a divorce decree dissolving the parties' marriage. COUNT II EOUlT ABLE DISTRIBUTION 9. Plaintiff repeats and realleges paragraphs one through eight. 10. Plaintiff and Defendant have acquired property during the marriage, including, but not limited to: a) Defendant's pension with the State of Pennsylvania WHEREFORE, Plaintiff respectfully requests the Court to divide this property equitably between the parties, and to provide such other relief as the Court deems just. Date l\ \ \'2-- \ 0 Lj (, \ k- ,-,]0 fl~ (1,,~ ~;;ail.Jll. Sala7/:.g: .>l:y. U Certified Legal Intern ~d~t1- (/ . PLACE0 ROBE E. RAINS ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 VERIFICATION 1 verifY that the statements made in this Divorce Complaint are true and correct to the best of my personal knowledge and belief. 1 understand that false statements herein are made subject to penalties of 18 Pa. C. S. S 4904, relating to unsworn falsification to authorities. Date: 4 s . 04 Q -e.MA-'~~vtVvvev-L1---lA~ -rirri Blumenthal TERRI BLUMENTHAL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : DIVORCE o tt - ,~'7<r : No. CIVIL TERM MICHAEL BLUMENTHAL, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Terri Blumenthal, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party . Date L\ l \ L \OLI Respectfully submitted, Cu\~ l~ ~ - . on O.AX" (2.:>r'M Abi;ilJ.W~w~ 0 Certified Legal Intern ~-ft ROBERT E. RAINS ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 II SANDRA C. RITTER-BUTZ, Plaintiff/Petitioner vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA DAVID G. BUTZ, Defendant/Respondent CIVIL ACTION - CUSTODY NO. 03 -1574 NOT ICE T 0 D E FEN D You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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. Court Administrator Cumberland County Court House Fourth Floor 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-620Cl ~ tJr:() /.)., Mary ~. Etter Dissin r Attorney for Plainti f II SANDRA C. RITTER-BUTZ, Plaintiff/Petitioner vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA DAVID G. BUTZ, Defendant/Respondent CIVI.L ACTION - CUSTODY NO. 03-1574 PETITION FOR EMERGENCY RELIEF AND F'OR IMMEDIATE TRANSFER OF PHYSICAL CUSTODY AND NOW, comes the Plaintiff/Petitioner, Sandra C. Ritter- Butz, by and through her attorneys, Dissinger and Dissinger, and files the following petition for emergency relief and for immediate transfer of physical custody and in support thereof avers as follows: 1. Petitioner is Sandra C. Ritter-Butz, mother of the children, who resides at 703 Alberta Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. Respondent is David G. Butz, father of the children, who resides at 113 May Drive, Apartment 4, Camp Hill, Cumberland County, Pennsylvania. 3. Petitioner seeks custody of the following children: Name Present Residence Age Tyler David Ritter-Butz 703 Alberta ~~enue Mechanicsbur9, PA 17050 13 Korbin Patrie Ritter-Butz 113 May Drive Apartment 4 Camp Hill, PA 17011 12 II .. 4. The children were not born out of wedlock. 5. The child, Tyler David Ritter-Butz, is presently in the custody of Sandra C. Ritter-Butz, who resides at 703 Alberta Avenue, Meehanicsburg, Cumberland County, Pennsylvania. The child, Korbin Patrie Ritter-Butz, is presently in the custody of David G. Butz, who resides at 113 May Drive, Apartment 4, Camp Hill, Cumberland County. 6. During the past five years, the children have resided with the following persons at the following addresses: Persons Sandra C. Ritter-Butz David G. Butz Tyler David Ritter-Butz Korbin Patrie Ritter-Butz Sandra C. Ritter-Butz David G. Butz Tyler David Ritter-Butz Korbin Patrie Ritter-Butz Sandra C. Ritter-Butz Tyler David Ritter-Butz Korbin Patrie Ritter-Butz Sandra C. Ritter-Butz Tyler David Ritter-Butz David G. Butz Korbin Patrie Ritter-Butz Addresses 764 Erford Road Camp Hill, PA 17011 Date 10/01/94- OS/24/98 703 Alberta Avenue Mechanicsburg, PA 17050 OS/25/98- 01/24/03 703 Alberta Avenue Meehanicsburg, PA 17050 01/24/03- 02/16/03 703 Alberta Avenue Mechaniesburg, PA 17050 02/16/03- present 113 May Drive Apartment 4 Camp Hill, PA 17011 02/16/03- present 7. The present custody arrangement is pursuant to Court Order, dated May 27, 2003, and attached hereto as Exhibit "A." II 8. Respondent/Father has represented to Petitioner/Mother that he intends to move to Lancaster, Pennsylvania, with the parties' child, Korbin Patrie Ritter-Butz. 9. Respondent/Father has also indicated that there is nothing Petitioner/Mother can do to stop him from taking the child to Lancaster. 10. While there is a Court Order governing the custody arrangement, Petitioner/Mother believes that Respondent/Father will move with the child without seeking permission to relocate from the Court. 11. If Respondent/Father takes Korbin Patrie Ritter-Butz to Lancaster, the child would enter his third school district in a one (1) year period. 12. As Petitioner/Mother is disabled and unable to drive, it is likely that Korbin Patrie Ritter-Butz would be precluded from seeing his mother and his brother on a regular basis. 13 . that from The Court Order, dated May 27, 2003 (Exhibit "A"), directs parties to obtain a custody evaluation and recommendation Dr. Stanley Schneider. 14. The parties and the children have been seeing Dr. Schneider for over a year now and Dr. Schneider has not and does not intend to issue a custody recommendation as of this date, in large part due to Respondent's failure to pay for the cost of the evaluation, which is his obligation under the Court Order of May 27, 2003. 15. Petitioner/Mother requests immediate transfer of custody of Korbin Patrie Ritter-Butz to her in order to preserve her II . i relationship with the child and the child's relationship with his brother. WHEREFORE, Petitioner/Mother respectfully requests that, until further Order of Court, primary physical custody of both children be awarded to her and that Respondent/Father be permitted to have periods of temporary custody as ordered by the Court or as the parties may agree. Respectfully submitted, DIllSINGER AND DISSINGER BY:~~A/) c'~~~ -- Mary . Etter Dissin Attorney for Petitioner Supreme Court ID #27736 28 N. 32nd Street Can~ Hill, PA 17011 (717) 975-2840 II .1 ! VERIFICATIOIN' I, Sandra C. Ritter-Butz, 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. !l4904, relating to unsworn falsification to authorities. /'\ '\,' ! /' ~ ) /7/11//(1/(7 '--- . Sandra C. Rit MAY', 23 ro03 {Y , iU '.. ~~ 1 ~ ~ SANDRA C. RITTER-BUTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERL.AND COUNTY, PENNSYLVANIA \'s. 03-1574 CNIL ACTION LAW DAVID G. BUTZ Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ 1 day of consideration of the attached Custody Conciliation Report, it i " , 2003, upon rdered and directed as follows: 1. The parties shall submit themselves and their minor Children to a custody evaluation to be performed by Stanley Schneider, Ed.D, or other professional selected by agreement of the parties. The purpose of the evaluation shall be to obtain independent prof(:ssional recommendations concerning ongoing custody arrangements which will best serve the needs of the Children. The Father shall be responsible to pay all costs of the evaluation initially, but reserves the right to request that the Court allocate a portion of the cost to the Mother at a later date. The parties shall sign any authorizations deemed necessary by the e\'aluator to obtain additional information pertaining to the Children or the parties. 2. The Mother, Sandra C. Ritter-Butz and the Father, Davis G. Butz, shall have shared legal custody of Tyler David Ritter-Butz, born May 21, 1990, and Korbin Patric Ritter-Butz, born March 19, 1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 3. On a temporary basis pending completion of the custody evaluation and further agreement of the parties or Order of Court, the parties shall have physical custody of the Children as follows: A. The Mother shall have primary physical custody of Tyler and the Father shall have primary physical custody of Korbin. EXHIBIT I "All B. The parties shall alternate having custody ofbollh Children on weekends from Friday at 3:00 pm through Sunday at 6:00 pm, beginning with the Father having custody on Friday, May 16, 2003. C. Rather than using daycare, the Mother shall have custody of Korbin before school, (when the Father is not transporting the Child dir~:tly to school) and after school until the Father picks up the Child after work. The Fatrn:r shall transport Korbin to the Mother's residence on his way to work in sufficient time for the Child to ride the bus to school from the Mother's residence. D. The Mother shall also have custody of Korbin during the summer school break on weekdays when the Father is working and the Child is not attending camp. The Father shall transport Korbin to and from the Mother's residence before and after work. E. In 2003, the Mother shall have custody of the Children over the Memorial Day weekend from Friday at 3:00 through the holiday at 6:00 pm, and the Father shall have custody over the July 4th holiday from July 1 at 3:()0 pm through July 4th at 6:00 pm. 4. The parties agree that the Children shall attend their respective summer camps and the parties shall share transportation to and from the Children's camps and other activities. 5. The party relinquishing custody of a Child or Children 'shall provide the receiving parent with a list of medications, and the time for administration of the medications, to be given during that party's period of custody. The parent relinquishing custody shall also provide a written notation of all medications which were administered during his or her period of custody. 6. Each party shall notify the other party of all medical appointments scheduled for either Child in advance. 7. Both parties shall refrain from discussing divorce, support or custody issues in the presence or hearing of the Children and from making legal papers and correspondence accessible to the Children. 8. Neither party shall use illegal drugs or consume alcohol to the point of intoxication during his or her periods of custody. Both parties shall ensure that third parties having contact with the Children comply with this provision. 9. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. '. 10. Both parties shall ensure that neither Child has access to guns or other dangerous weapons. 11. Upon completion of the custody evaluation, counsel for either party may contact the conciliator within sixty days ofreceipt of the evaluator's written recommendations to schedule an additional conciliation conference, if necessary, Counsel for either party may contact the conciliator to request the scheduling of a telephone conference with counsel if, after following the temporary before and after school schedule for a period of at least two weeks, either party believes the arrangement is having a detrimental effect on either Child. 12. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ~ cc: Mary A. Etter Dissinger, Esquire - Counsel for Mother Paul J. Helvy, Esquire - Counsel for Father ..;... ~.. . . .... Prot onotary " SANDRA C. RITTER-BUTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLi\ND COUNTY, PENNSYLVANIA vs. 03-1574 CNIL ACTION LAW DAVID G. BUTZ Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Tyler David Ritter-Butz Korbin Patric Ritter-Butz May 21, 1990 March 19, 1992 Mother Father 2. A Conciliation Conference was held on May 14, 2003, with the following individuals in attendance: The Mother, Sandra C. Ritter-Butz, with her counsel, Mary A. Etter Dissinger, Esquire and the Father, Daivd G. Butz, with his counsel, Paul J. Helvy, Esquire. 3. The parties agreed to entry of an Order in the form as attached, with the exception of the temporary arrangements under which Korbin would go to the Mother's residence on the bus with Tyler after school until the Father finishes work, which is the recommendation of the conciliator on a temporary basis. The Father objected to this arrangement stating that Korbin does not want to go to the Mother's home and has been doing well in after-school day care. The Mother believes it would be best if the Children could spend this time together after school (as primary custody is currently split) and feels it is a preferable arrangement to daycare as the Mother is willing and able to provide care for the Child until the Father's work day is over. Date ~ 1'1: d-tJ,:)3 [)~ - 1.- Q~~ Dawn S. Sunday, ESqUl Custody Conciliator " SANDRA C. RITTER-BUTZ, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF Cl~BERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION - CUSTODY DAVID G. BUTZ, Defendant/Respondent NO. 03-1574 CERTIFICATE OF SE:RVICE I, Mary A. Etter Dissinger, hereby certify that on the date set forth below I served a true and correct copy of the Emergency Petition for Custody upon J. Paul He1vy, Esquire, attorney for David G. Butz, Defendant/Respondent, by First Class United States mail addressed as follows: J. Paul Helvy, Esquire 218 Pine Street Harrisburg, PA 17101 Date: va2/Of/ , --/ ~~ ~Z-~~~ Mar A. Etter Dissing~ II ,I ~\ \. .-^.., '"... r. ~ r --. CII C-- .-- c:<' ~, fL ~ d ~ c: '''<, , () "11 ,",4 :;-..', '. "q f;"\ ~_:::: ,-i1 '.:J , ('~ ~! ,~-) j'll , r'," r<':; ;-',.) ,'-' ... ! -~'" . TERRI BLUMENTHAL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : DIVORCE MICHAEL BLUMENTHAL, Defendant : No. 04-1574 CIVIL TERM VERIFICATION OF SERVICE Understanding that the making of any false statement would subject The Family Law Clinic to the penalties of 18 Pa. C.S. 94904 (relating to unsworn falsification to authorities), the undersigned verifies that Abigail J. W. Salawage mailed a true copy of a Divorce Complaint on the Defendant by placing the same in the U.S. Mail, certified no. 7002 0860 0001 58478707, restricted delivery, return receipt requested, postage prepaid, on the 13th day of April, 2004 addressed as follows: Michael Blumenthal 315 South Pitt Street Carlisle, P A 17013 Sender's receipt no. 7002 0860 0001 58478707 is attached hereto and incorporated by reference. On the 26th day of April, 2004, green return receipt no. 7002 0860 0001 58478707 was delivered to the Family Law Clinic, bearing the signature Michael Blumenthal and showing a date of service of April 23, 2004 The return receipt is attached hereto and Dated:~O)Q[J)I GM~JJ~lDsif Abigail J. . Sala age CJ Certified Legal Intern F AMIL Y LAW CLINIC 45 N. Pitt SI:. Carlisle, PAl 70 13 717-243-2968 incorporated by reference. C RetIlm Rec8lpt Fee ..I] (Endo-_ ot] _DelIvelyFee C (Endof8ement Recitftd) ru _ Pootogo &FOOl $ Postage $ I" c l"- .., l"- ::r- ot] '" .-'I C C C Certified Fee ~ nt. ~ ............~".~:............_.....".. ~~:~:~:......~..~..?......~.~_..:f._~..___.___ __,___,___.. en" StlI...z"... a.'l~~<"., ,oA ~l.'~13 PS Form 3800, April 2002 See ncvpr' ..' ~ ~ ~ 0 ... = ""tJf:t ..... -"1 ~ [pcn """ .... J " ::r:::n ) 7r!-~ ::0 ~ (t))- c.., r'l;=::: -,-' ~ :By! a ) ,....t~ 0 ~C1 0 ;.to. h. -0 --I .J 2:'; --'-""1" ;:- (-- :Jl: (";.:; :ti J>(~t:! r:-::> 70 ..::;: c5rn ~ c.n ::r;.! ='X] N -< ) l } ) TERRI BLUMENTHAL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : DIVORCE MICHAEL BLUMENTHAL, Defendant : No. 04-1574 CIVIL TERM INVENTORY OF PLAINTIFF. TERRI BLUMENTHAL Plaintiff files the following inventory and appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory and appraisement are true and correct. Plaintiff understands that false statements herein are made subject to the penalties ofl8 Pa.C.S. !}4904 relating to unsworn falsification to authorities. J '------- ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. (X) I. Real property ( ) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( ) 5. Checking accounts, cash ( ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) II. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits - severance pay, workman's compensation claim/award ( ) 17. Profit sharing plans (X) 18. Pension plans (indicate employee contribution and date plan vests) ( ) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits ( ) 24. Debts due, including loans, mortgages held ( ) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number Description of ProDertv Names of All Owners 315 South Pitt S1. Carlisle, PA 17013 Michael Blumenthal 18 Pension from Pennsylvania State Employees Retirement Services Michael Blumenthal NON-MARITAL PROPERTY Plaintiff lists all property in which a Spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description of ProDertv Reason for Exclusion PROPERTY TRANSFERRED Item Number Description of Prooertv Date of Transfer Consideration Person to Whom Transferred LIABILITIES Item Number Description of Prooertv Names of All Creditors Names of All Debtors Plaintiff reserves the right to correct and/or supplement this Inventory to the extent that she acquires additional information regarding assets and/or liabilities. >' =~ ...., c:.~, r;::~ ""- L (- f:::: o .1 ---j ffi ::I! ,- -~,fn ~-;.jy ,) . -:ICJ ..'-' -Y', ','; ,~.. ({l u:> -,.., c..' (" (Jl NANCY BULLOCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM C. BULLOCK, Defendant : CIVIL ACTI0N- LAW : NO. 1576-2004 : IN CUSTODY STIPULATION REGARDING CUSTODYNISITATION Plaintiff Nancy Bullock, hereinafter referenced as "Mother," and Defendant William C. Bullock, hereinafter referenced as "Father," hereby agree to the following terms in an Order defining custody and partial custody rights and responsibilities in relation to William C. Bullock, Jr., born 10/6/89, and David S. Bullock, born 7/1192, hereinafter referenced as "Children:" 1. Mother and Father will share legal custody of the children as defined in 23 Pa. C.S.A. ~5302. All decisions affecting the children's growth and including but not limited to medical treatment, education, and religious training, are major decision which Mother and Father shall make jointly after discussion and consultation with each other. 2. As provided in 23 Pa. C.S.A. ~5309(a), each parent shall have full and complete access to the children's mental, dental, religious and school records. This includes the names, addresses and telephone numbers of all medical and other providers. 3. Mother shall have primary physical custody of children, and Father shall have periods of partial custody every other weekend from Friday evening at 5:30 PM until Sunday evening at 5:30 PM, beginning the weekend of July 30,2204. Father shall also have partial custody of the Children during the on his days off from work provided that he gi yes Mother 48 hours notice. 4. The Mother shall have the Children on Mother's Day and the Father shall have the Children on Father's Day. 5. The parties shall share the following holidays as follows: Easter Memorial Day 4th of July Labor Day Thanksgiving Schedule A Thanksgiving Schedule B Christmas Schedule A Christmas Schedule B New Years Eve New Years Day Even # Years M F F M M F F M F M Odd # Years F M M F F M M F M F Easter runs from Saturday evening at 5:00 PM until SW1day afternoon at 2:00 PM. Memorial Day runs from 5:00 PM the evening before until 4:00 PM Memorial Day July 4th runs from July 3rd at 4:00 PM until July 5th at 9:00 AM. Labor Day runs from 5:00 PM the evening before until 4:00 PM Labor Day Thanksgiving Schedule A runs from Wednesday, Thanksgiving Eve at 6:00 PM until Thursday, Thanksgiving Day at 4:00 PM. Thanksgiving Schedule B runs from Thursday, Thanksgiving Day at 4:00 PM until Friday evening at 4:00 PM. Christmas Schedule A runs from 12:00 PM Christmas Eve until 12:00 PM Christmas Day. Christmas Schedule B runs from 12:00 PM Christmas day until 12:00 PM December 26th every year, or as otherwise agreed upon by the parties. New Years Eve Schedule runs from 12:00 PM New Years Eve until 12:00 PM New Years Day New Years Day Schedule runs from 12:00PM New Years Day unti112:00PM January 1, every year, or as otherwise agreed upon by the parties. 6. Holidays take precedence over the other provisions in this Stipulation. 7. Father shall have children for seven (7) consecutive days to go on vacation, after Labor Day, but prior to Memorial Day, for an educational vacation with approval from the children's school. 8. Visitation may be at such other times as the parties mutually agree. 9. The parties shall keep each other advised immediately relative to any emergencies concerning the Children and shall further take any necessary steps to ensure that the health, welfare and well being of the Children are protected. The parties shall do nothing that may estrange the Children from the other party or hinder the natural development of the Children's love or affection for the other party. 10. Neither party shall mllke any disparaging remarks regarding the other party in the presence of the child. Additionally, neither party shall permit third persons to make disparaging remarks concerning the other party in the presence of the child. I I. Any modification or waiver of any of the provisions of this Agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the Agreement of the parties. 12. The parties hereto acknowledge that they have had the opportunity to consult an attorney prior to executing this Agreement. Mother's attorney is Karl E. Rominger, Esquire. Father's attorney is Nathan C. Wolf, Esquire. 13. The parties hereto agree that this Agreement shall be recorded and incorporated into an Order enforceable by the Court. Consented to: Date 7; ZiP -01 '( ""-:::J /1 ;1~ Nancy Bullock 1 ,Jt 0 0 1-- COO./ Karl ~linger, ~qUi;e Date 7-&~-'DY Date ~~~ {"-~r:# - William C. ]~OCk ~:d ~~qUire 7 - Z:J - z-<v--I Date C) "-' 0 C,2) C~ c:-:) --n .r L_ ... :C """ C_~_ \ \m; r'':':- r- -, i-on ,,-, C! -. i ~;) . .,'1 ':'l \.0 )rn ! =~ c'') . I 0 -<. TERRI BLUMENTHAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM PRAECIPE TO WITHDRAW EQUITABLE DISTRIBUTION COUNT To the Prothonotary: Please withdraw the Count for Equitable Distribution in the above-captioned Complaint for Divorce filed in the Cumberland County Courthouse on Aprill3, 2004. ~ Date: JlA--t I h I 16 / t,~'i~ "eV q(l Anne MacDonald-Fox Thomas Place Robert Rains Supervising Attorneys The Family Law Clinic 45 N. Pitt Street Carlisle, P A 17013 (717) 243-2968 "', = = "-", o ." ..... :r: rll::IJ , -nfTl ,~;S\) -~;C,) :--r', ;',-5:0 >,C) '~5fTI ~'~l -~ :.:'<: "" ...,- r:--? Cl m TERRI BLUMENTHAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM CERTIFICATE OF SERVICE I, Jeffrey Stovall, hereby certify that I am a competent adult and that the Family Law Clinic served a correct copy of the Plaintiffs Affidavit under ~3301(d) of the Divorce Code on April 13,2004, to Michael Blumenthal's attorney, Taylor Andrews, by regular U.S. mail, postage prepaid, at 78 West Pomfret Street, Carlisle, PAl 7013. 1 verify that the statements made in this certificate are tme 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: ~(zr(C0 F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 0 ...., 0 C::..? {'.~ e.::;-, "'fl '-Y' .~ ,- :T (--- rr; r-" ",--' r'-...! a' "J -' '."') -, c.:: '" TERRI BLUMENTHAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION-LAW DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM NOTICE OF INTENTION TO REOUEST ENTRY OF ~ 330Hd) DIVORCE DECREE TO: Michael Blumenthal, Defendant: Terri Blumenthal intends to file with the court the attached Praecipe to Transmit Record on or after August 16, 2005 requesting that a final decree in divorce be entered. -AVL.VJ\' Date 1!j ZdJS"' I s: / I!!~ey . Stoval efi ntern Jil, [l ) 9r"'~ ~IJ~9t\- ROBBItt R RAINS THOJ\1AS PLACE LUCY JOHNSTON-WALSH ANNJE MACDONALD-FOX Counsel for Defendant Supervising Attorneys F AMIL Y LA W CLINIC 45 N.Pitt S1. Carlisle, PA 17013 o -n ~ '~7\ (.f) '~2, -:') \ -' ,...-f' -'- o r- .'., TERRI BLUMENTHAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION-LAW DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM CERTIFICATE OF SERVICE I, Jeffrey Stovall, hereby certity that on this 7th day of September, 2005, I am serving a true and correct copy of the Praecipe to Transmit Record and Divorce Information Sheet to Michael Blumenthal's attorney, Taylor Andrews by first class U.S. mail, addressed as follows: Taylor Andrews, Esq. 78 West Pomfret St. Carlisle:, PA 17013 Date: 7/,/6) F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 o' ~~ () c:;.:;o "n <;.J" (,0 r-;:-\ , -' 0J o TERRI BLUMENTHAL, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION-LA W DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of divorce decree: I. Ground for divorce: unilateral no fault under ~ 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted deliver, return receipt requested, postage prepaid. Service was complete Upon receipt by Michael Blumenthal, April 23, 2004. 3. Date of execution of the Affidavit required by ~ 3301 (d) of the Divorce Code: April 9, 2004. Date of filing of Plaintiff's Affidavit: April 13,2004. Date of service of Plaintiff's Affidavit upon Defendant: April 23, 2004. 4. Related claims pending: none. 5. Notice ofIntention to file Praecipe was served to Defendant's counsel, by regular United States mail, first class, postage pre' July 27,2005, a copy of which is attached. A \Jtos, l1, 21l.Y:] ~ Date - eflTey. I Ce . ed Legal Intern ~fiM ~1i/!l;~o:L ROBE, . RAINS THOMAS PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Counsel for Defendant Supervising Attorneys F AMIL Y LA W CLINIC 45 N, Pitt St. Carlisle, P A 17013 f'<l ,-::> .~..;;:,;l ~.r1. ,~ (:J -1'1 :~~1 c') CJ 0"1 - TERRI BLUMENTHAL, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL BLUMENTHAL, DEFENDANT 04-1574 CIVIL TERM ORDER OF COURT AND NOW, this l~ day of September, 2005, the praecipe for the entry of a final decree in divorce IS DENIED at this time,1 By ~C~ · Ed-::{ B.~,y, J Jeffrey G. Stovall, Certified Legal In ern Lucy Johnston-Walsh, Esquire Supervising Attorney For Plaintiff ~~~ q - '1--0,5 ,]lJS Taylor P. Andrews, Esquire For Defendant :saJ 1 The praecipe to transmit the record states that "NoticEl of Intention to file Praecipe was served to Defendant's counsel, by regular United States mail, first class, postage prepaid on July 27, 2005, a copy of which is attached." The document is not attached. ::/-if)8 SO: ! I I'tl !j I dJ$ SDUZ .,.r!~>j 31-11 .:!O :::):-}_X)-{i~l!:J TERRI BLUMENTHAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM AMENDED PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of divorce decree: I. Ground for divorce: unilateral no fault under S 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Michael Blumenthal, April 23, 2004. 3. Date of execution of the Affidavit required by S 3301 (d) of the Divorce Code: April 9, 2004. Date of filing of Plaintiffs Affidavit: April 13, 2004. Date of service of Plaintiffs Affidavit upon Defendant: April 23, 2004. 4. Related claims pending: none. 5. Notice ofIntention to file Praecipe was served to Defendant's counsel, by regular United States mail, first class, postage pnlpaid on July 27, 2005, a copy of which is attached. O~ 6. Order of Court denying the entry of a final decree: in divorce was entered on 1;" C:?' 13,2005, '"0" of which i, __Ol~ ere ey . Stovall Certified Legal Intern ;itJ~~ l/LUC STON-WALSH Counsel for Defendant Supervising Attorney F AMIL Y LAW CLINIC 45 N. Pitt St. Carlisle, P A 17013 Date (") ,.., ~ = ~,; = en if> :?:o \"'fl .-.:; fl'r- N -dill 7IJY 0:> ~~r~ -0 :z: ~~C'i r:Y ::srn ~ " N ~ ,r;- .- lJ TERRI BLUMENTHAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION.LA W DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 330Hd) DIVORCE DECREE TO: Michael Blumenthal, Defendant: Terri Blumenthal intends to file with the court the attached Praecipe to Transmit Record on or after August 16, 2005 requesting that a final decree in divorce be entered. 0'7/7-'7/05' Date I I ~ G 0,,11 ": . led Legal Intern ~~ . RAINS THO AS PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX COlmsel for Defendant Supervising Attorneys F AMIL Y LAW CLINIC 45 N. Pitt St. Carllisle, P A 17013 n '" >,'", r-; ~:;:;. '-'" SA ~o '" co -0 :::;:.: Q, ~ifP ---q,tD '"';..>Y <'~?\ (~?, ->..:-.:.:\ IJ c-, ':''?i''''I'"l ~.;':') , '.:::.\ "?Q .4 '" ." l" "" TERRI BLUMENTHAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM CERTIFICATE OF SERVICE I, Jeffrey Stovall, hereby certify that on this 28th day of September, 2005, 1 am serving a true and correct copy of the Praecipe to Transmit Record and Divorce Information Sheet to Michael Blumenthal's attorney, Taylor Andrews by first class U.S. mail, addressed as follows: Taylor Andrews, Esq. 78 West Pomfret St. Carlisle, P A 170 I3 Date: 09/1cg!Oj ~'.I ~ egal Intern F AMIL Y LAW CLINIC 45 Nortll Pitt Street Carlisle, PA 170I3 l-Y ,....> 0 c;? c: c-,", ." , ,~.; c-" if) 1-::n r-n ~-x::; (Ile _..,,".1 l'-' .1")0 CO ;~\r!' -0 ...i.. .A~ 1-r1 ~ ~?\ N 55 :;..- :..<, , DIVORCE INFORMATION SHEET PURSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT REQUIRED BY THE STATE EFFECTIVE JANUARY 1, 2002. THE PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE. DOCKET NUMBER: ()-f - 15'1 '-f DATE OF MARRIAGE: ?:'(-:'I/~O TERRI BLUMENTHAL, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL BLUMENTHAL, DEFENDANT 04-1574 CIVIL TERM ORDER OF COUR1[ AND NOW, this t~ day of September, 2005, the praecipe for the entry of a final decree in divorce IS DENIED at this time.1 Jeffrey G. Stovall, Certified Legal Intern Lucy Johnston-Walsh, Esquire Supervising Attorney For Plaintiff Taylor P. Andrews, Esquire For Defendant :sal f~, r;i~r.~nc;~~r'~rer.:n:~CO~ " ldO S't~ CII saM Coo Carllsl$ ~ JP · . '4n> . F\'othon I The praecipe to transmit the record states that "NotiCE! of Intention to file Praecipe was served to Defendant's counsel, by regular United States mail, first class, postage prepaid on July 27, 2005, a copy of which is attached," The document is not attached. TERRI BLUMENTHAL, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL BLUMENTHAL, DEFENDANT 04-1574 CIVIL TERM ORDER OF COURT AND NOW, this?- '\ day of September, 2005, the amended praecipe for the entry of a final decree in divorce, IS DENIED at this time.1 By th7C6urt, / / Jeffrey G. Stovall, Certified Legal Intern Lucy Johnston-Walsh, Esquire Supervising Attorney For Plaintiff '.~ ~ , j. .;}<I_o~ Taylor P. Andrews, Esquire For Defendant Cf-.. :sal 1 The notice of intention to request entry of as 3301 (d) divorce signed on July 27, 2005, and belatedly filed on September 28, 2005, does not conform with the notice required in Pa. Rule of Civil Procedure 1920.73. Ali,~"." ~" -! , " l'h... fJS : I :.!d 6Z d3S ~OOl ''''V.I "'.1"" '-,' 'd "Hl -10 AU ....lJl\tJd.i\.....:(.,,;:; :;. 3Ji:I,'O--CElll:l TERRI BLUMENTHAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION-LAW DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM AMENDED PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of divorce decree: 1. Ground for divorce: unilateral no fault under 9 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Michael Blumenthal, April 23, 2004. 3. Date of execution of the Affidavit required by 9 3301 (d) of the Divorce Code: April 9, 2004. Date of filing of Plaintiff's Affidavit: April 13, 2004. Date of service of Plaintiff's Affidavit upon Defendant: April 23, 2004. 4. Related claims pending: none. 5. Amended Notice ofIntention to file Praecipe was served to Defendant's counsel, by regular United States mail, first class, postage prepaid on October 17,2005, a copy of which is attached. Je . Stovall . led Legal Intern ') /tU. o STON-WALS Coun 1 for Defendant Supervising Attorney F AMIL Y LAW CLINIC 45 N. Pitt S1. Carlisle, P A 17013 NM,\,>,,!)11Z Date /l1,uPY , r C) ~~:;-<' '- TERRI BLUMENTHAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM AMENDED NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE TO: Michael Blumenthal, Defendant: Terri Blumenthal intends to file with the court the attached Praecipe to Transmit Record on or after November 7,2005 requesting that a final decree in divorce be entered. CtWCi"rl. 17/ 1~)S- Date ' l-A ~LJd-tL ROBE INS THOMAS PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Counsel ti)r Defendant Supervising Attorneys F AMIL Y LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 > . 0 - --- TERRI BLUMENTHAL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION.LA W DIVORCE MICHAEL BLUMENTHAL, Defendant No. 04-1574 CIVIL TERM CERTIFICATE OF SERVICE I, Jeffrey Stovall, hereby certify that on this 14th day of November, 2005, I am serving a true and correct copy of the Amended Praecipe to Transmit Record and Divorce Information Sheet to Michael Blumenthal's attorney, Taylor Andrews by first class U.S. mail, addressed as follows: Taylor Andrews, Esq. 78 West Pomfret S1. Carlisle, PA 17013 I) t . N?t&i\rPl It I ].cV') a e. / $:; Certified Legal Intern FAMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 ,,',' ---- ". .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +;f + + ~++++.+.+.+.+.+.+++++.++.++++++++++++++++++++++++++++~ . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;t;+++ . ++++ +++++++++++++++++ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF 'l'ERRI BLUMENTHAL, Plaintiff No. VERSUS MICHAEL BLUMENTHAL, Defendant DECREE DIVORCE AND NOW,-1l(~ (7 DECREED THAT TERRI BLUMENTHAL AND MICHAEL BLUMENTHAL ARE DIVORCED FROM THE BONDS OF MATRIMONY. PENNA. 1574 2004 IN .,-- ~~ IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT '"c COC"~ /) \ {A.AA/ // t NONE By ATTEST: ~~~~~~~~~~~~~~~~~ +++++++++++++++++++++ ./ ,// . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +++++:++++'f++++ , PROTHONOTARY +'f++++:+:+++++++++++ J. v~? ;f/:'..1 ~ /{!"pv'"I r":;}:.i1i1.., .J.P' It' - )! . 1:J 'J../vvvvt I ftrI;;J ;::"V 5:/ Ie - l . .~ ..,' ,'0 ,