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HomeMy WebLinkAbout09-7124Z) Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 GRETA M. FARRELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 71;ZA4 L`T MARC J. FARRELL, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT, if you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 GRETA M. FARRELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 9 / a y.? ?t vrx? MARC J. FARRELL, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Greta M. Farrell, an adult individual residing at 1402 Chatham Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Marc J. Farrell, an adult individual residing at 541 S. Third Street, Lemoyne, Cumberland County, Pennsylvania 17043. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on October 1, 1994 in New Cumberland, Cumberland County, Pennsylvania. 5. There are three (3) minor children born of this marriage being Michael J. Farrell (Born: January 17, 1998), William T. Farrell (Born: December 7, 2000), and Lucie R. Farrell (Born: January 12, 2004). 6. There have been no prior actions for divorce or annulment between the parties. 7. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 8. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE FAULT 9. The averments in paragraphs 1 through 8, inclusive of Plaintiffs Complaint are incorporated herein by reference thereto. 10. Plaintiff is the innocent and injured party, and Defendant has offered such indignities to the person of the Plaintiff and has been mentally cruel and barbarous to her so as to make her life burdensome and her condition intolerable, in violation of the marriage vows and of the laws of the Commonwealth. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in accordance with the Pennsylvania Divorce Code. NO FAULT 11. The averments in paragraphs 1 through 10, inclusive of Plaintiffs Complaint are incorporated herein by reference thereto. 12. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. COUNT II EQUITABLE DISTRIBUTION 13. The averments in paragraphs 1 through 12, inclusive of Plaintiffs Complaint are incorporated herein by reference thereto. 14. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance with Section 3501 of the Pennsylvania Divorce Code. COUNT III SUPPORT. ALIMONY PENDENTE LITE AND ALIMONY 15. The averments in paragraphs 1 through 14, inclusive of Plaintiffs Complaint are incorporated herein by reference thereto. 16. Plaintiff requires reasonable support to adequately sustain herself with the standard of living established during the marriage. WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite. COUNT IV ATTORNEY'S FEES AND COSTS 17. The averments in paragraphs 1 through 16, inclusive of Plaintiffs Complaint are incorporated herein by reference thereto. 18. Plaintiff is unable to sustain herself during the course of this litigation and has employed Barbara Sumple-Sullivan, Esquire as counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel, and the necessary and reasonable costs and expenses. WHEREFORE, Plaintiff requests an award of counsel's fees and expenses. WHEREFORE, Plaintiff, Greta M. Farrell, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; B. Equitably distributing the marital property; C. Awarding Plaintiff support, alimony and alimony pendente lite; D. Awarding Plaintiff counsel fees, costs and expenses; and E. Awarding other relief as the Court deems juo,64 reasonable. Dated: October 16, 2009 1 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 GRETA M. FARRELL, : IN THE COURT OF COMMON PLEAS Plaintiff V. MARC J. FARRELL, Defendant CUMBERLAND COUNTY, PENNSYLVANIA : NO. CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT REGARDING COUNSELING 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Dated: 2009 ? GRETA FARREL10 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 GRETA M. FARRELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MARC J. FARRELL, Defendant : NO. CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, Greta M. Farrell, hereby certify that the facts set forth in the foregoing Pleading are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: Q 2009 GRETA M. ARRELL Cory le ? - ao ,07 2609 OCR 19 ?'? t?' 2 ? F rri'afv? ?.. °Y 14.. So Oct- 9? y I Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 GRETA FARRELL, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ; Docket No. 2009 - 7124 MARC J. FARRELL, Order No. 00816 S 2009 Defendant PACSES No. 320111173 APPEAL OF ORDER AND REQUEST FOR HEARING DE NOVO TO THE PROTHONOTARY: Please accept this as an Appeal of the Order dated October 19, 2009 and schedule the matter for De Novo Hearing before the Support Master. Dated: November 4, 2009 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court No. 32317 Attorney for Plaintiff e Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 GRETA FARRELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. Docket No. 2009 - 7124 MARC J. FARRELL, Order No. 00816 S 2009 Defendant PACSES No. 320111173 CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the APPEAL OF ORDER AND REQUEST FOR HEARING DE NOVO, in the above-captioned matter upon the following individual, via United States first-class mail, postage prepaid, addressed as follows: Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043 DATE: November 4, 2009 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff FfLEU E ?p?/ Jl H' '` "Fly y ?tti 12 2009 NOV -5 Art 9= 29 6a -v Dg 6 pY Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 GRETA M. FARRELL, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Oq- 7l 0"2 L.l MARC J. FARRELL, CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Samuel L. Andes, Esquire, hereby accept service and acknowledge receipt of the above- captioned Divorce Complaint on behalf of Defendant, Marc J. Farrell, having received said Complaint on the Z,# day of October, 2009. Samuel L. Andes, Esquire Attorney for Defendant 525 North Twelfth Street P.O. Box 168 Lemoyne, PA 17043 717-761-5361 Supreme Court ID No. 17225 FILE '-- - FO THE 2009 NOV 10 Vii' r y! MAti?t"" ? i .Jf GRETA M. FARRELL, ) IN THE COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA vs. MARC J. FARRELL, Defendant NO. 2009-7124 CIVIL TERM CIVIL ACTION -LAW OBJECTION TO PROPOSED SUBPOENA AND NOW comes the above-named Defendant, by his attorney, Samuel L. Andes, and files the following objection to the issuance of the subpoena duces tecum which the Plaintiff proposes to serve upon Members First Federal Credit Union. Defendant's objections are based upon the following: 1. The proposed subpoena is over broad in that it requests information about Defendant's engagement as an attorney by Members First Federal Credit Union in 2006, 2007, and 2008, during which time he was not engaged as an attorney by the Credit Union and Plaintiff is well aware of that. 2. The issuance and service of the subpoena jeopardizes Defendant's professional relationship with the Credit Union in that it will cause unnecessary work on the Credit Union and threatens to expose professional confidences and secrets which the Credit Union has reposed in Defendant. 3. The subpoena represents an improper intrusion upon the attorney-client relationship between the Defendant and the Credit Union. 4. The information which Plaintiff seeks by the subpoena is available to her directly from Defendant, who is prepared and willing to make that information available, and can be confirmed by 1099 statements and other official reporting documents which will be issued to Defendant by the Credit Union. 5. Defendant believes that the subpoena is requested in bad faith and in an effort to professional embarrass him with his most important client. WHEREFORE, Defendant asks this Court to decline to issue the subpoena requested by Plaintiff and directed to the Members First Federal Credit Union. uel L. A des Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that on 3 ~ ~~' ° ~ ~e ,.~, s ~;~ 2009, I served a copy of the foregoing document upon counsel for Plaintiff by U.S. Mail, postage prepaid, addressed as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 el L. Andes Attorney for Defendant Supreme Court ID 17225 P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 GRETA M. FARRELL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO.2009 - 7124 MARC J. FARRELL, :CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff, Greta M. Farrell, intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: November 13, 2009 arbar~ple-Sullivan, Esquire 9 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Attorney for Plaintiff Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 GRETA M. FARRELL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - 7124 MARC J. FARRELL, :CIVIL ACTION -LAW Defendant IN DIVORCE SUBPOENA DUCES TECUM To: Members 1St Federal Credit Union Attn: Security 5000 Louise Drive P.O. Box 40 Mechanicsburg, PA 17055 Within (20) days after service of this subpoena, you are ordered by the Court to produce the following documents or things to the law office of Barbara Sumple-Sullivan, Esquire at 549 Bridge Street, New Cumberland, Pennsylvania ] 7070: 1) Documentation of all accounts payable, accounts receivable and any other compensation due to Mr. Marc J. Farrell and/or Central PA Patent & Trademark Law Group, LLC for work performed from 2006 to the present. You may deliver or mail legible copies of the documents or produce other things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a Court Order compelling you to comply with it. This subpoena was issued at the request of the following person: Barbara Sumple-Sullivan, Esquire Supreme Court ID#: 32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 BY: Prothonotary/Clerk, Civil Division Date: SEAL Deputy Official Note: This form of subpoena shall be used whenever a subpoena is issuable, including hearings in connection with depositions and before arbitrators, masters, commissioners, etc. in compliance with Pa. R.C.P. No. 234.1. If a subpoena for a production of documents, records or things is desired, complete paragraph. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 GRETA M. FARRELL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2009 - 7124 MARC J. FARRELL, :CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of Notice of Intent to Serve a Subpoena, in the above-captioned matter upon the following individual, by United States first-class mail, postage prepaid, addressed as follows: Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043 Date: November 13, 2009 1~3arbara Sumple-Sullivan, Esquire Attorney for Plaintiff Supreme Court I.D. 32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 ^ - -n ~ r L,'~ V ... .;r, 2C~~ ~~~ -1 P7 G~ ~ I _ _ ti GRETA FARRELL, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. :DOMESTIC RELATIONS SECTION MARC J. FARRELL, PACSES NO. 320111173 Defendant :DOCKET NO. 816 SUPPORT 2009 GRETA M. FARRELL, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner :CUMBERLAND COUNTY, PENNSYLVANI,9~ . C"~ ...-.. p ` 'f'j V. :DOMESTIC RELATIONS SECTION-~:?i--` ~-- ; MARC J. FARRELL, . ~ _ ~. , i') ~F -_ ~ Defendant/Respondent :DOCKET NO. 09-7124 CIVIL '-~` :.~~~ _ ~ ; -~` -.,; ORDER OF COURT ' ~ ` ~ ~~~ -,-~ ....-s ~1 ~ c.~ •'~: AND NOW, this 26th day of January, 2010, 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 on the Plaintiff's claim for alimony pendente lite, and the parties having reached an agreement on all outstanding issues, upon recommendation of the Master, it is ordered and decreed as follows: 1. The interim order entered October 19, 2009 is affirmed as a final order. 2. Said order is modified effective January 1, 2010 such that the Defendant shall pay to the Pennsylvania State Collection and Disbursement Unit as support for his children, Michael Farrell, born January 17, 1998, William Farrell, born December 7, 2000, and Lucie Farrell, born January 12, 2004, the sum of $1,650.00 per month, and in all other respects said order shall remain in full force and effect. 3. Any arrearages or credit existing through December 31, 2009 are hereby remitted. 4. The Plaintiffs claim for spousal support is dismissed without prejudice. 5. The Plaintiffs claim for alimony pendente lite is dismissed without prejudice. By the Court, ~` 14 M. . Ebert,, Jr., J. Cc: Greta Farrell Marc J. Farrell Barbara Sumple-Sullivan, Esquire For the Plaintiff Samuel L. Andes, Esquire For the Defendant DRO/tjc GRETA M. FARRELL, PLAINTIFF V. MARC J. FARRELL, DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7124 CIVIL IN RE: PLAINTIFF'S PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 14t" day of April, 2010, upon consideration of Greta M. Farrell's Petition for Special Relief and after a status conference in the matter held on Wednesday, April 14, 2010, the Court having scheduled a full hearing on the matter for July 8, 2010; IT IS HEREBY ORDERED AND DIRECTED that Defendant, Marc J. Farrell, shall secure a term life insurance policy in the amount of $150,000.00 which names Greta M. Farrell as the beneficiary of the policy. Defendant shall maintain the policy in full affect until further Order of Court. By the Court, ~ Barbara Sum le-Sullivan p ,Esquire Attorney for Plaintiff ~muel L. Andes, Esquire Attorney for Defendant bas .~/ ~ ~~ ~~ ~~ M. L. Ebert, Jr., J, n ^a C `_ °._:. ~ ~, ~' ~ ~ - ~~ ~ .., .~_ c -' _ N ~ ~ ` ' ~ ~ ~ ' - - - ~'' t ~ ~ t `j ~ : ~ ~ . ~_1 ']~ ~ / GRETA M. FARRELL, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. MARC J. FARRELL, DEFENDANT NO. 09-7124 CIVIL ORDER OF COURT AND NOW, this 1St day of July, 2010, upon consideration of the request by the parties for a continuance of the hearing scheduled for Thursday, July 8, 2010, IT IS HEREBY ORDERED AND DIRECTED that the hearing is continued. Either party may request the matter be rescheduled if needed. By the Court, Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff ~muel L. Andes, Esquire Attorney for Defendant bas C o~~ E.s rn~ ~ ~~ I 7/~ ~~ M. L. ert, Jr., J• n a ; C C.~ i~ t ~ -~ ~ ~ ~ ~_r. ~,;. ~. ~: - . ~_, ~~ A .S'- ~ ,~ - G F°,' `-- „. -- p! o P I~u~ q t~~. ~ ~t(~ ..,..,; !; -':- GRETA M. FARRELL, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) NO. 2009-7124 CIVIL TERM MARC J. FARRELL, ) Defendant ) CIVIL ACTION -DIVORCE PETITION FOR LEAVE TO WITHDRAW AND NOW comes Samuel L. Andes, and petitions the court for leave to withdraw as counsel for the Defendant Mazc J. Farrell, based upon the following: 1. Petitioner is Samuel L. Andes an attorney admitted to the Baz of this County and the Commonwealth of Pennsylvania who maintains offices at 525 North 12~' Street, P.O. Box 168 in Lemoyne, Pennsylvania. 2. He has represented the Defendant Mazc J. Farrell in this matter. The Defendant's mailing address is Central Pa Patent & Trademazk Law Group, LLC, P.O. Box 2441 in Harrisburg, PA 17105 3. The Plaintiff in this matter is Greta M. Farrell and she is represented by Bazbaza Sumple Sullivan, Esquire. 4. Your Petitioner is no longer able to competently and professionally represent the Defendant because of Defendant's failure to cooperate with and follow the advice of Petitioner. Defendant has consistently ignored Petitioner's advise or acted contrary to it. 5. Defendant has advised Petitioner that he does not want Petitioner to represent him any further and will make arrangements either to represent himself or to obtain other counsel. However, as of the date of this Petition, Defendant has done neither. 6. Without the active cooperation of Defendant, Petitioner cannot properly fulfill his obligations as an attorney in this matter or as an officer of this court. 7. Prior matters in this matter have been assigned to the Honorable M.L. Ebert, Judge of this Court. 8. Petitioner has provided a copy of this Petition to Defendant and to Plaintiffl s counsel and has not received any response. As a result, Petitioner cannot state whether the parties to this action concur in his Petition or not. WHEREFORE, Petitioner prays this court to grant him leave to withdraw as counsel for Defendant for Marc J. Farrell. 1 L. Andes Attorney at Law Supreme Court ID # 17225 525 North 12~' Street P.O. Box 168 Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: ~~j - ~ SAMUEL L. ANDES CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing document herein by regular mail, postage prepaid, addressed as follows: Barbara Sumple Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Marc J. Farrell, Esquire Central PA Patent & Trademark Law Group, LLC P.O. Box 2441 Harrisburg, Pa 17105 Date: 5 August 2010 Am arkins Secretary for Samuel L. Andes a AGG 10 2010 GRETA M. FARRELL, ) Plaintiff ) vs. ) MARC J. FARRELL, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-7124 CIVIL TERM CIVIL ACTION -DIVORCE ORDER OF COURT AND NOW this 11~ day of ~ V q v i~ , 2010, upon consideration of the attached Petition, a Rule is hereby issued upon both the Plaintiff and the Defendant to show cause, if any they have, why Samuel L. Andes, should not be granted leave to withdraw as the attorney for the Defendant Marc J. Farrell in this matter. The Rule shall be served upon Defendant by regular mail and upon Plaintiff's counsel of record. The Rule shall be returnable '~,~ days from date of service. BY THE COURT, Distribution: ~ Samuel L. Andes, Esquire (Petitioner) ~~ ~.' -- ~ _ -,-I 525 North 12th Street, P.O. Box 168, Lemoyne, PA 17043 `~' -' ~ ~. ~ Barbara Sumple Sullivan, Esquire (Attorney for Plaintiff) 549 Bridge Street, New Cumberland, Pa 17070 ~ ` ~ -: ~ =~ !~ Marc J. Farrell, Esquire ~ ~ + _~ ~ ~~ , ~_ Central PA Patent & Trademark Law Group, LLC -` ~ `~ P.O. Box 2441, Harrisburg, Pa 17105 ~op~tS ixa .ltd ~j<!~o n n 'PONOTARRY 2010 OCT 13 AM !C: I ' CUMBER! AND COUN"i- Y VP GRETA M. FARRELL, Plaintiff VS. MARC J. FARRELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-7124 CIVIL TERM CIVIL ACTION - DIVORCE MOTION TO MAKE RULE ABSOLUTE AND NOW comes Samuel L. Andes, who moves the Court to make absolute the Rule it issued on 11 August 2010, based upon the following: 1. The moving party, Samuel L. Andes, filed a motion for leave to withdraw as counsel for the Defendant, Marc J. Farrell, in early August, 2010. Prior to his filing the motion, he served copies of it upon both the Defendant and the attorney for the Plaintiff, Barbara Sumple-Sullivan, Esquire. Confirmation of that service is set out in the Certificate of Service attached to the original motion. 2. This Court issued a rule upon both the Plaintiff and the Defendant to show cause why Mr. Andes' motion should not be granted, by an Order dated 11 August 2010. 3. Mr. Andes served copies of the Court's Rule by regular mail in accordance with the Court's Order, upon both the Defendant and the attorney for the Plaintiff. Filed contemporaneously with this motion is a Certificate of Service confirming service of the Court's Rule on those parties. 4. No person has filed an answer or other response to this Court's Rule and no party has objected to the relief requested by Mr. Andes in his original motion for leave to withdraw. 5. The prior order in this matter was entered by the Honorable M.L. Ebert, J. Mr. Andes believes that Plaintiff and Defendant concur in the relief requested in this motion because they have not filed any objection to his request to withdraw. WHEREFORE, Samuel L. Andes moves the Court to make absolute its Rule issued on 11 August 2010 to allow him to withdraw as attorney for Defendant in this matter. Samu L. Andes Attorney at Law Supreme Court ID # 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: I o SAMUEL L. ANDES CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing document herein by regular mail, postage prepaid, addressed as follows: Barbara Sumple Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 Marc J. Farrell, Esquire Central PA Patent & Trademark Law Group, LLC P.O. Box 2441 Harrisburg, Pa 17105 Date: 12 October 2010 Samuel L. Andes GRETA M. FARRELL, Plaintiff VS. MARC J. FARRELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-7124 CIVIL TERM CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE I hereby certify that I served an original of the Court's Order of 11 August 2010 upon the Defendant, Marc J. Farrell, and upon counsel for Plaintiff by regular mail, postage prepaid, addressed as follows: Barbara Sumple Sullivan, Esquire 549 Bridge Street "s (= ", D New Cumberland, PA 17070 rn C, - n -? M r7 rte - Marc J. Farrell, Esquire - , ' Central PA Patent & Trademark Law Group, LLC ve r - ::=-n P.O. Box 2441 c ) a_= c, --n Z -- Harrisburg, Pa 17105 >- r- Date: 12 October 2010 Samuel L. Andes i~~ ~ i -. ,,-.._ ~ '°• ~ ' ';„ t a F 4~Q~Qf ~~~' OF TH pRaTNONQTARY 2010 OCT 18 AM 9~ 03 CU PENNSYLVANIA TY GRETA M. FARRELL, Plaintiff vs. MARC J. FARRELL, Defendant ORDER f~~` '~ ~~QIU ~~ 14 2D10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-7124 CIVIL TERM CIVIL ACTION -DIVORCE th AND NOW this 15 day of ~c,~o~ ~~' , 2010, upon the motion to make our Rule absolute in this matter, it appearing that our Rule was served in accordance with our Order of August 11, 2010, and that no answers or objections have been filed by any party, we hereby make absolute our Rule issued on August 11, 2010. Samuel L. Andes, Esquire, is granted leave to withdraw as counsel for the Plaintiff, Marc J. Farrell, in this matter. BY THE COURT, ~~ ~. alb p Y g ~I'Olarc J. Farrell, Defendant, Central PA Patent & Trademark Law Group, LLC, P.O. Box 2441, Harrisburg, PA 17105 ~~s m~~l~ ~o /g~10 Distribution: Sa~'~e) L. Andes, Petitioner, P.O. Box 168, Lemoyne, PA 17043 B r ra Sum le Sullivan Attorne for Plaintiff 549 Brid a Street New Cumberland PA 17070 `~'r~'~ €=l~~il-0~=~=iC~ 1.,s^. y ~~~D a~'T 20 Pik 3: G~.? GRETA 1~. FARRELL, ) Plaintiff ) ~s. ) MARC J. ~'ARRELL, ) Defendant ) i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-7124 CIVIL TERM CIVIL ACTION -DIVORCE PRAECIPE TO THE PIt~OTHONOTARY: Plea$e withdraw my appearance for the Defendant Marc J. Farrell in the above matter 20 October 010 Samuel L. Andes Attorney at Law Supreme Court ID # 17225 ~ 525 North 12"' Street P.O. Box 168 Lemoyne, Pa 17043 (717) 761-5361 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 l? -- r ?012JAN2d A????52 __. a.?n rn11N'TY GRETA M. FARRELL, Plaintiff V. MARC J. FARRELL, Defendant TO THE PROTHONOTARY: : F W VU? OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-7124 CIVIL ACTION - LAW IN DIVORCE PRAECIPE Please withdraw Plaintiff, Greta M. Farrell's, claims for: 1) Equitable Distribution pursuant to §3502 of the Divorce Code; 2) Support, Alimony Pendente Lite and Alimony pursuant to §3701 and §3702 of the Divorce Code; and 3) Attorney's Fees and Costs pursuant to §3323 of the Divorce Code. DATE: 1 2. - Barbara Surnple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attorney for Plaintiff Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 GRETA M. FARRELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MARC J. FARRELL, Defendant NO. 09-7124 CIVIL ACTION -LAW IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Praecipe to Withdraw, in the above-captioned matter upon the following individual by postage prepaid, as follows: Marc Farrell, Esquire 1109 Columbus Avenue, Apt. 1 Lemoyne, PA 17043 DATED: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. No. 32317 Attorney for Plaintiff Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 'J THE P OTMONOTARy 2012 JAN 20 AM 11: 50 GRETA M. FARRELL, Plaintiff V. MARC J. FARRELL, Defendant IN THE COiB N0X PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 19, 2009. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the 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 this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: , 2012 G TAM.F L z ,E PROTKNOTAR Barbara Sumple-Sullivan, Esquire Supreme Court #32317 201 Z J AN 20 AM 1 1 5 2 549 Bridge Street New Cumberland, PA 17070 CUMBERLAND COUNTY (717) 774-1445 pENNSYLVANIA GRETA M. FARRELL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. MARC J. FARRELL, Defendant . NO. CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of 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 that false statement herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unsworn falsification to authorities. DATE: (Z, 2012 .. wa )??aqw G M. F L V Ft,- 41LED-oFFICEE OHONOTAi Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street 2012 JAN 20 AM 11: 52 New Cumberland, PA 17070 717 774-1445 CUMBERLAH GRETA M. FARRELL, rtKWtVNftURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-7124 MARC J. FARRELL, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 19, 2009. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the filing and service of the Complaint. 3. Additionally, as set forth in Defendant Marc J. Farrell's Request for Entry of §3301(d) Divorce Decree (which Plaintiff acknowledges), filed November 16, 2011, it is undisputed that the parties have been separated since at least May 17, 2009, a period of two (2) years and eight (8) months. 4. Defendant's consent is conditioned upon Plaintiff's agreement to waive, with prejudice, any and all past, present and future claims (whether asserted or not). 5. Matters between the Parties relating to custody and child support remain in dispute, and will be litigated separately from this action. 6. 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 this affidavit are true and correct. I understand that V false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsifications to authorities. Marc J. Farrell (Sup. Ct. ID 81933) Mailing Address: Central PA Patent & Trademark Law Group, LLC P.O. Box 2441 Harrisburg, PA 17105-2441 Home Address: 1109-01 Columbus Avenue Lemoyne, PA 17043 (717) 503-5104 Faffell@CentralPaPatent.com Representing Himself Date: January 18, 2012 -2- Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 GRETA M. FARRELL, Plaintiff V. MARC J. FARRELL, Defendant TNT OTHONOTA f ?; y 2012 saN z0 An 11: 52 CUMBERLAND COUNTY PEt'NNSYL"NI A THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of 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. 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 that false statement herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unsworn falsification to authorities. 0 DATE: Jpn. 19 , 2012 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 H;7 PROTHONOTARY 2 j7 jAN 20 APB 11' S3 GRETA M. FARRELL, Plaintiff V. MARC J. FARRELL, Defendant L 't*M1!1fbTMT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7124 CIVIL ACTION -LAW 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 §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Counsel for Defendant accepted service of the Complaint on October 20, 2009. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff: January 10, 2012; by Defendant: January 18, 2012. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in §3301(c) January 20, 2012. Date Defendant's Waiver of Notice Prothonotary: January 20, 2012. Dated: / was filed with Prothonotary: l (c),Divprce was filed with Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 GRETA M. FARRELL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-7124 MARC J. FARRELL, : CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Plaintiffs Praecipe to Transmit Record, in the above- captioned matter upon the following individual by postage prepaid as follows: Marc Farrell, Esquire 1109 Columbus Avenue, Apt. Lemoyne, P. 17043 DATED: l zi'_ (717) 774-1445 Supreme Court I.D. No. 32317 Attorney for Plaintiff JT7 1J11%A V ""WWL New Cumberland, PA 17070 Greta M. Farrell V. Marc J. Farrell IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7124 DIVORCE DECREE AND NOW, Sgr 11? A VAOt4, XYL it is ordered and decreed that Greta M. Farrell _, plaintiff, and Marc J. Farrell bonds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. 14 E E By the Court, /Vo f j Ice cod y a? a? ' rf t? c?P ? C _ rn CU rri IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL CIVIL ACTION - LAW ma c-) :X , GRETA M. FARRELL Plaintiff vs. MARC J. FARRELL Defendant FILE NO. 09-7124 20 IN DIVORCE NOTICE TO RESUME PRIORS Notice is hereby given that the Plaintiff/)tgt in the above matter, having been granted a Final Decree in Divorce on the 25th day of January, 2012 hereby elects to resume the prior surname of GRETA M. BOWRING and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: 2 2 ,Z COMMONWEALTH OF PENNSYLVANIA U•L ks-&a Signat W:k pj-?? Signature of being toned SS. COUNTY OF CUMBERLAND On the _ day of ? ?D u1Y? , 20?, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my NOTARIAL SEAL BARBARA SUMPLE-SULLIVAN Nogty Prbk W CUMBERLAND BOO, CUMALAMM My Cow bow Nw 15. WIS seal Notary Public X13 0o PA A-rt'Y d*QRl(o Plt- I'1,2Q3 171 IA: aI'rVt iAAVI1 deb:. ?,t W!a AQAgiiAB ;?#wuq y%toiF