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HomeMy WebLinkAbout09-7482 THOMAS LEE THOMAS, SR., Plaintiff vs. CHERIESE THOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. a 9 - 7y?-;` Civil Term ACTION IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO, OR TELEPHONE, THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 t THOMAS LEE THOMAS, SR., Plaintiff vs. CHERIESE THOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Q Imo- 74/ra- Civil Term : ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Thomas Lee Thomas, Sr., a competent adult individual, who resides at 1361 Zimmerman Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Cheriese Thomas, whose current address is 220 Shipman Road, Apt. D-19, Havelock, NC, 28532. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on August 10, 2005 in Jacksonville, North Carolina. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have one child together, namely, Thomas Thomas, Jr. A custody Order regarding this child is filed in Cumberland County under Docket No. 2009 - 3560. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. l 1 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: (of zg/o9 Thom homas, Sr., Plai_, Respectfully submitted, Far e Adams, Esquire No. 79465 West South St. lisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF r II. k THE FTARY 1Q?gOCT 29 2. 05 ?- 3 3 g• g d? c? °`??' l S c,/-O 5-3-5/7 1ANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esclad amsC~ gmail.com THOMAS LEE THOMAS, SR., Plaintiff vs. CHERIESE THOMAS, Defendant „r Fc~~~=r,; , `-' ?etc" f',~3,r~-,?n,{~~.r~~ 2410 FEL -5 p~ ~: ~~ ~U~~,'~ ,~:'; r~ ~1~~~~~y~ cf1,~~y~j~~s,~tt~4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09 - 7482 Civil Term ACTION IN DIVORCE FATHER'S PETITION FOR CONTEMPT AND NOW comes the Plaintiff/Petitioner Thomas Lee Thomas, Sr., by and through her Attorney, Jane Adams, and respectfully represents the following: 1. Petitioner is Thomas Lee Thomas, (hereinafter referred to as "Father") who currently resides at 1361 Zimmerman Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Respondent is Cheriese Thomas, (hereinafter referred to as "Mother"), who currently resides at 220 Shipman Road, D19, Havelock NC, 28532. 3. The parties are the natural parents of one child, namely, Thomas Lee Thomas, Jr., born May 14, 2007. 4. The parties are currently subject to an Order of Court, dated October 4, 2009, a copy of which is attached hereto as Exhibit A. 5. Paragraph 3 of the October 7, 2009 Order provides that Father would have week long periods of physical custody with the child in October, November, and December. ~.~~~ 5,1~ '~ ~3 733 (~ 6. Mother has refused to provide any of Father's periods of physical custody with the child because she "can't get transportation" and "doesn't have time." 7. Because of Mother's refusal to provide physical custody, Father has not seen the child since October 2009. 8. There is a custody hearing scheduled before this Honorable Court on February 26, 2009. No additional time periods of physical custody are provided for Father between the date of filing of this petition and the date of the hearing. 9. Mother has not offered Father any make-up time for the missed visits and continues to unilaterally deny Father any periods of partial custody. 10. Father is requesting that Mother be found in contempt of the court Order entered in this matter, be ordered to pay reasonable sanctions, and attorney's fees, and be ordered to provide Father with make-up visits with his child. 11. This matter was previously assigned to Judge Ebert. 12. To Father' s knowledge and believe, Mother does not agree with the relief requested in this petition. 13. Mother is self-represented, as her Counsel recently withdrew his appearance. WHEREFORE, Petitioner, Thomas Lee Thomas, respectfully requests that this Honorable Court set a hearing regarding his petition far Contempt in this matter. Respectfully submitted, oa~e: ZI SI ~~ 'Jan Adams, Esquire I. . No. 79465 W. South St. Carlisle, Pa. 17013 (717) 245-$508 ATTORNEY FOR FATHER THOMAS LEE THOMAS CHERIESE N. THOMAS, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2009-3560 CIVIL ACTION -LAW THOMAS-LEE THOMAS, . Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of ~-~a ~ E'l,~,~_, 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. A Hearing is scheduled in Court Room No. ~, , of the Cumberland County Court House, on the ~ day of ~ , 20 ~ ~, at /y;p(,> o'clock, ~. M., at which time testimony will be taken. F purposes of this Hearing, the Mother shall be deemed to be the moving party and shall proceed initially with testimony. Counsel for each party shall file with the Court and opposing counsel a Memorandum setting forth each party's position on custody, a list of witnesses who will be expected to testify at the Hearing and a summary of the anticipated testimony of each witness. These Memoranda shall be tiled at least five days prior to the Hearing date. 2 Pending further Order of Court or agreement of the parties, the prior Order of Court dated June 26, 2009 shall remain in full. force and effect with the following modifications and additions. 3. Father shall have the following periods of partial .physical custody: A. ~ Sunday, October 11, 2009 at 12:00 noon to Sunday, October 18, .2009 at 2:00 p.m. Father shall be responsible for all transportation. • - ' ~ ~ ~ r•. ~ ` B. ~ V~ednesday, November 25, 2009 at 5:00 p.m. to Wednesday, _ - ~ ~ December 2, 2009 at 5:00 p.m. Mother shall be responsible for all . transportation. All exchanges made in Carlisle shall be at the Carlisle _ ~ _ Police Station. ., C. Saturday, December 26, 2009 at 3:00 p.m. to Saturday, January 2, ' ~ 2010 at 3:00 p.in. Mother shall be responsible for dropping the child off to Father at the beginning of Father's custodial period and Father shall be responsible for returning the child to Mother at the end of his custodial period. All exchanges made in Carlisle shall be at the Carlisle Police Station. 4• Father shall have his parents or sister provide day care for the child. ~• Reasonable telephone contact shall be one call, every other day, between the hours of 6:00. p.m. and 8:00 p.m. Father shall provide a cell phone number for Mothe-• to contact the child. 6• 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, .L. ert, Jr., J. cc: Jame Adams, Esquire, counsel for Father Nathan C. Wolf, Esquire, counsel for Mother TRUE ~}~~~ ~`~"~~. €~~,~~ )n Test~r~~~~y ~:~terUcf, 1 here uritn sit ~~ bend end fihe seal of said Courfi at Carlisle, Pa. tl~~ ..~:`hy Q~.. .:.~.:.., _ .~.. . P onn~~r~ CHERIESE N. THOMAS, Plaintiff V. THOMAS-LEE THOMAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2009-3560 CIVIL ACTION -LAW IN CUSTODY PRIOR JUDGE: M.L. EBERT, JR., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Thomas Lee Thomas, Jr. May 14, 2007 Mother 2. A Conciliation Conference was held on October 5, 2009 with the following individuals in attendance: The Mother, Cheriese N. Thomas, by telephone, with her counsel, Nathan C. Wolf, Esquire, and the Father, Thomas-Lee Thomas, with his counsel, Jane Adams, Esquire. 3. The Honorable M.L. Ebert, Jr., previously entered an Order of Court dated June 2, 2009. providing for shared legal custody, Mother having primary physical custody and Father having one week per month, Sunday to Sunday, with the parties exchanging cusfody.in Richmond, Virginia. - 4: Mother's position on custody is as follows: Mother seeks shared legal and primar"y physical custody, with Father having two consecutive weeks every other month. Mother 11as relocated to North Carolina and is attending school. She believes this schedule would minimize transportation. She has concerns over Father's choice of babysitter when he is at work. She suspects it is a girlfriend, who she is not familiar with and has concerns whether she is properly caring for the child. 5. Father's position on custody is as follows: Father seeks shared legal and shared physical custody on a month on/month off schedule. He currently lives with his Mother, and indicates his Mother or other family member cares for the child while he is at work. Since the child is too young to be in school, Father would like to maximize his time with him. 6. The Conciliator recommends an Order in the form as attached scheduling a Hearing and modifying the prior Order. It is expected that the Hearing will require one day. VERIFICATION I verify that the statements made in this Custody Petition 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: 1~~ /p Th ma a homas, i loner CERTIFICATE OF SERVICE AND NOW, this February 5, 2010, I, Jane Adams, Attorney for Father, Thomas Lee Thomas, hereby certify that a copy of Father's Petition for Contempt has been duly served upon the Mother by placing such in the custody of the United States Postal Service, via certified mail, postage pre-paid addressed to: Cheriese N. Thomas 220 Shipman Road, D19 Havelock NC 28532 DEFENDANT SELF-REPRESENTED ne Adams, Esquire . D. No. 79465 17 W. South Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR FATHER THOMAS THOMAS THOMAS LEE THOMAS, SR., IN THE COURT OF COMMON PLEAS ~ , Plaintiff :CUMBERLAND COUNTY, PENNSYLVAI~A ~ ~'~i rr , ~ Ya , ~.. _ --r't vs. No. 09 - 7482 Civil Term ~`' fv -?; c~ __'~", CHERIESE THOMAS, :ACTION IN DIVORCE - -~? , Defendant = - f ~ ~ ~.; l-r-~ - .. .: ~ :~ CERTIFICATE OF SERVICE ~ ~' ''` I, Jane Adams, Esquire, do hereby certify that on February 22. 2010. I served a true and correct copy of the AFFIDAVIT OF SEPARATION AND COUNTER- AFFIDAVIT in the above-captioned matter upon the following individual(s) by certified mail, restricted, return receipt requested, addressed as follows: Patrick Shaffer, Certified Legal Intern Family Law Clinic 44 N. Pitt St. Carlisle, Pa. 17013 f , . FOR DEFENDANT ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the cans to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Signature X /~ ^ Agent ^ Addressee B: Received by P-Inte erne) C. Date of Delivery ~ , C~~ c~7'ZZ Ja D. Is delivery address different from Item 1? t9'T~ If YES, enter delivery address below: ^ No ~~~~~~ ~~ iV ~/~ ~T ~~ `"~,,^""'' ~ 3. Service type ~~ 1~ { r p ' ~ (~.-~- ' ^ Certified Mail O Express Mall ~ ~l J ^ Registered 0 Retun Fiecelpt for Merrhandlse ~~~~~'~ ~`~ ^ Insured MeB ^ C.O.D. 4. Restricted De1Nwy't (Extra Fee) ^ Yes 2' per 7DD9 282D DDD2 2103 9896 (nanafbr 8om service ~abef) PS Form 3811, February 2004 Domestic Return Receipt iozsss~o2-M-t~o , pectfully Submitted: a e Adams, Esquire . No. 79465 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF I=? LED-OI= r I F i s ROTNO CITE 2011 SEP 14 AM 11: 17 OUMBERLAND COUNT`;, PENNSYLVANIA THOMAS LEE THOMAS, SR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 09 - 7482 Civil Term CHERIESE THOMAS, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 2009. 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on October 29, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: (3, \,? ? N ---- : ThonAzs Le a3 dpr s, Sr., P ntiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) AND 43301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 1 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 statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: 1,1 Tho as Lee T r., Plaintiff THOMAS LEE THOMAS, SR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 7482 Civil Term V. ACTION IN DIVORCE CHERIESE THOMAS, Defendant C= =M rn = ^° 'r Z: AFFIDAVIT OF CONSENT ?rn r-- -r cs C:) cw -g C, ?: C7 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on &tol?r 29, 2009. 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date 4 O \ 1 , Cheriese Thomas, Defendant ?J THOMAS LEE THOMAS, SR., Plaintiff V. CHERIESE THOMAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 7480. Civil Term : ACTION IN DIVORCE c -? 3 rn? ? m to ? c? 3>C-, =C:) ;;c-- N a cn rn w CA C7 ?rn C11 uM x=w WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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 statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date [ (!T?? CAN-0 A,^-UD?2 Cheriese Thomas, Defend t r..) C +v c- THE COURT OF COMMON PLEAT i& ` -?- Tnomas Lee Thomas, Sr., IN PENI`tSY1 N TY , 1W PLAINTIFF , CUMBERLAND COUN V. r y fi" `D NO. 09-7482 Civil Term Cheriese Thomas, ACTION IN DIVORCE=': rte - -- ;: DEFENDANT MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this day of 1 , 2011, by and between Thomas Lee Thomas, Sr.. of Carlisle, Cumberland County, Pennsylvania, and Cheriese Thomas, of Carlisle, Cumberland County, Pennsylvania, concerns marital debts and property. Except as to child support, which is separate and apart from this Agreement, and except as set forth herein, this Agreement is intended to constitute a full and final settlement of all economic issues relating to the marriage and divorce of the parties. WHEREAS, plaintiff, Thomas Lee Thomas, Sr., hereinafter "Husband," and defendant, Cheriese Thomas, hereinafter "Wife," desire to enter into an agreement as to the distribution of their marital debt and property, Wife and. Husband agree to the following: SEPARATION The parties have lived. separate and apart since March, 2009. SETTLEMENT PAYMENT 2. Beginning on October 1, 2011, Husband shall pay Wife two hundred fifty ($250.00) dollars a month, by money order or in cash, for the next six (6) months, until the total amount that Husband has paid Wife is one thousand five hundred dollars ($1, 500.00). Husband's monthly payment shall be due on the 1St day of each month, and time shall be of the essence. In the event that Husband is more than ten (10) days past due on any payment, the entire amount shall become immediately due and owing, and Wife shall be entitled to bring an action for contempt and/or to enforce against Husband for the entire amount, as well as interest and/or attorneys' fees, as provided in paragraph 10. Each party shall execute any necessary documents to finalize their Divorce within ten (10) days of Wife's receipt of the first two hundred fifty ($250.00) dollar payment referenced in paragraph 2. MUTUAL RELEASE 4. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators, and assigns, release and discharge the other of and from all causes of action, claims, rights or demands, whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for child support, divorce, or any action to enforce this Agreement. ALIMONY, ALIMONY PENDENTE LITE SPOUSAL SUPPORT,. COSTS AND COUNSEL FEES Both parties waive spousal support, alimony, alimony pendente lite, costs, and counsel fees, and agree not to make any such claims in the future, except in connection with an action to enforce this Agreement as set out in paragraphs 10 and 11. PERSONAL PROPERTY 6. The parties have agreed to a division of their personal property, and it is understood and agreed that each party shall retain as his or her sole and separate property, free and clear of any claim of the other, all of those items of personalty which each now has in his or her respective possession or control. DEBTS 7. Husband represents and. warrants to Wife that he will not contract. or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and hold Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him, except as set forth in this Agreement. 'Wife represents and warrants to Husband that she will not contract or incur any debts or liabilities for which Husband or his estate might be responsible and shall indemnify and hold Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her, except as relating to child support, medical treatment of their son, Brandon, or as otherwise set forth in this Agreement. WAIVER OF CLAIMS AGAINST ESTATES 9. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may have or hereafter acquire under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, doNver, curtesy, statutory allowance, widow's allowance, right to take by intestacy, right to take against the will of the other, and right to act as administrator or ek:ecutor of the other's estate, and each will, at the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect thus mutual waiver and relinquishment of all such interests., rights and claims. This paragraph shall riot affect either party's right or power to expressly include the other party in any will or other document, whether written in the past or in the future. REMEDIES 10. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and seek any other remedies or relief as may be available to him or her, including claims for interest and attorneys' fees. 11.. Y?ny party who breaches this Agreement shall be responsible for payment of all legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief that may be available to him or her. This provision shall take precedence over the counsel fee waiver contained in paragraph 5 of this agreement. NO WAIVER OF DEFAULT 12. This Agreement shall remain in full force and effect unless terminated under the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such parry thereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. INTEGRATION 13. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. ADVICE OF COUNSEL 14. Husband agrees and understands that the Family Law Clinic represents only Wife's interests in this matter, and that; it cannot give him any legal advice, except that he should contact his own attorney. Husband understands this, and has chosen to proceed with counsel. 15. Each party confirms that he or she fully understands the terms, conditions and provisions of this Agreement and believes them to be fair, adequate and reasonable under the existing facts and circumstances. The parties further confirm that each is entering into this Agreement freely and voluntarily and that execution of this Agreement is not the result of any duress, undue influence, collusion, or improper or illegal agreements. INCORPORATION 1.6. The parties agree that the terms of this Agreement are legally binding, and further agree that this Agreement shall be incorporated, but not merged, into the divorce decree. This agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. 17. The parties intend that this Agreement be filed with the Court as satisfaction of the Equitable Distribution claim. However, the parties agree that failure to file this Agreement with the court shall have no effect on the parties' obligations or the ability to utilize any remedy for enforcement. IN WITNESS WHEREOF, the parties hereto have executed this Agreement the day and year first written above. Thomas as, S Cheriese Thomas; Plaintiff G Defendant C2 e AdamQs, Esq. A C 1.T D;++ C?a. ?.. ? So Lp?' Sf- Carlisle, PA 17013 o`?ys_ S Greg Marcelin Certified Legal Intern P THO S M. PLACE ROBERT E. RAINS ANNE MACDONALD-FOX MARTIN J. D'URSO MEGAN RIESrv1EYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax (717) 243-3639 ORDER AND NOW, this day of 2011, the foregoing Agreement V1\AWC_z 0t_tV_e0_ THOMAS LEE THOMAS, SR., IN THE COURT OF COMMON PLRO Plaintiff CUMBERLAND COUNTY, PENNSYl A vs. No. 09 - 7482 Civil Ternr ~` cn CHERIESE THOMAS, ACTION IN DIVORCE caa Defendant v PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please accept this request to transmit the record, together with the following information to the Court for entry of a divorce Decree: 1. Grounds for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and Manner of the service of the Complaint: served via certified process server, on January 22, 2010: affidavit of service of process filed on February 2, 2010. 3. Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: By Plaintiff: September 7, 2011 By Defendant: September 14, 2011 4. Related claims pending: None: all were resolved by the marriage settlement agreement. 5. Date Defendant's Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: September 14, 2011. 6. Date Plaintiff's Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: September 14, 2011. Respectfully sub Date: W. South St. Yrlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF I e Adams, Esquire . No. 79465 Cheriese Thomas, Plaintiff/ Petitioner V. Thomas-Lee Thomas, Defendant/ Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE No. 09-7482 CIVIL TERM Order of Court AND NOW, this')?1 day of _, 2012, upon consideration of the foregoing petition, it is hereby ordered that 1. A Rule is issue upon Defendant, Thomas Lee Thomas, to show cause why the relief granted by Plaintiff should not be granted; 2. Defendant shall file an answer to the petition within 'k,O days of this date. 3. The petition shall be decided under PA.R.C.P. No. 206.7; 4. Argument shall be held on , 2012 in Courtroom of the Cumberland County Courthouse; and ?- 5. Notice of the entry of this order shall be provided to all parties by the petitioner. ? 54,t - • Addk5, E-? Lao Qsq:c eo p; e s w a• `led J/a //a 4 BY THE COUR r., M M_ _i_. -? TO C? i } m-'7 Q CERTIFICATE OF SERVICE I, Anna Strawn, hereby certify that I am serving a true and correct copy of the Petition for Civil Contempt under 23 Pa.C.S. § 4346 on Thomas Lee Thomas by first class United States Mail. Date: Anna Strawn Certified Legal Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 CA) o c+ Cheriese Thomas, IN THE COURT OF COMMON PLEAS OF _- Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW M DIVORCE Thomas-Lee Thomas, Defendant/Respondent NO. 09 - 7482 CIVIL TERM ? =x iZ3 `? CERTIFICATE OF SERVICE I, Patrick Schaeffer, hereby certify that I am serving a copy of the Order of Court, dated May 2, 2012, by first class United States Mail upon the following person: Jane Adams, Esq. 17 W. South Street Carlisle, PA 17013 Attorney for Defendant/Respondent Date: May 3, 2012 ? ' Patrick Schaeffer Clinic Fellow FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 69 - P7j(8a CERTIFICATE OF SERVICE I, Anna Strawn, hereby certify that I am serving a true and correct copy of the Motion for a Continuance on Thomas Lee Thomas, by his Attorney, Jane Adams, at 17 W. South Street, Carlisle, PA 17013 by first class Untied States Mail- Date: : Anna Strawn Certified Legal Intern l THE FAMILY LAW CLI1C P 45 North Pitt Street Meer at ' - .- r Carlisle, PA 17013 = w c..? == (717) 243-2968 I? THOMAS LEE THOMAS, SR., . IN COURT OF COUNTCOMMON PENNSYLVANIA Plaintiff v : CIVIL ACTION - LAW IN DIVORCE CHERIESE THOMAS, Defendant : NO. 09-7482 CIVIL TERM ORDER OF COURT AND NOW, this 4?day ofY-4? , 2012, upon consideration of the attached Motion for Continuance, the motion is granted. Argument is hereby rescheduled for ?j a 12012 in Courtroom oZ of the Cumberland County Courthouse at q,0D -A ( 5 17 Date ? , At.11c Lao ekn `c. Jell- L r cr% C-j T.` BY THE COURT: 8. This matter has been assigned to Judge Ebert. WHEREFORE, Jane Adams, Esquire requests permission to withdraw her appearance for Thomas Lee Thomas from the above-captioned matter. Respectfully Submitted, Date: ~ 7J v J Adams, Esquire . . No. 79465 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF THOMAS LEE THOMAS, SR. THOMAS LEE THOMAS, SR., Plaintiff V. CHERIESE THOMAS, Defendant IN THE COURT OF COMMON PL SsF ~--: CUMBERLAND COUNTY, PENN9 .V~IIA -~ ~ _~-, NO. 09 - 7482 CIVIL TERM c~-~ ~~„ ~p we ~~ c~ ; CIVIL ACTION -LAW ~'"~ {~ =rte' ~ ~' ~ ~ "~ ~ c~-, ~, `•7D ---~ ~` ~ N ~-~ PETITION TO WITHDRAW AS LEGAL COUNSEL AND NOW COMES the Petitioner, Jane Adams, Esquire, and files the above- referenced Petition and represents that: 1. Petitioner is Jane Adams, Esquire, an Attorney duly authorized to practice law in the Commonwealth of Pennsylvania, having a principal place of business located at 17 W. South St., Carlisle, Pa. 17013 2. Petitioner is currently attorney of Thomas Lee Thomas, Sr., Plaintiff in the above-captioned matter. 3. Defendant is currently represented by the Anna Strawn at the Community Law Center, Carlisle, Pa. 4. Jane Adams was not able to communicate with her client before the contempt hearing, because he apparently changed his number. 5. Thomas !_ee Thomas has not honored the fee agreement he entered with counsel. 6. Counsel is requesting a Rule to Show Cause, to be served upon Thomas Lee Thomas, allowing her to withdraw her appearance, because she is unable to communicate with her client and he has not honored the fee agreement. 7. The Community Law Center previously indicated that they do not object to this request. t:~F 3'N ~RaTF~f71~4`~~~ ~+ THOMAS LEE THOMAS, SR., Plaintiff V. CHERIESE THOMAS, Defendant 1~`~~ AUG 30 AM 9~ ~ 7 CQ~TY iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANI NO. 09 - 7482 CIVIL TERM CIVIL ACTION -LAW ORDER OF COURT AND NOW, this ~~~ day of August, 2012, a Rule to Show Cause is issued upon Thomas Lee ~"homas, Sr., Plaintiff, to show why Jane Adams, Esquire, should n be permitted to withdraw her appearance. Rule returnable '~ ~ days after service upon Plaintiff, Thomas Lee Thomas Sr., via regular mail at 1361 Zimmerman Road, Carlisle, Pa. 17013. BY THE COURT: ~- cc: ~ Family Law Clinic / Thomas Lee Thomas ~in e 1~Qm5 ~ L s~` - ~9,~t ~.. L {~tia.~d ~~3D~~ ,~1~- .•- ~ . THOMAS LEE THOMAS, SR., PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHERIESE THOMAS, DEFENDANT NO. 09-7482 CIVIL ORDER OF COURT AND NOW, this 30~' day of August, 2012, upon consideration of Cheriese Thomas' Petition for Civil Contempt and after hearing in which the Plaintiff failed to appear and his counsel having moved to withdraw; IT IS HEREBY ORDERED AND DIRECTED that Thomas Lee Thomas, Sr., is found in contempt of the marital settlement agreement dated September 14, 2011. He is hereby ordered and directed to immediately pay the Defendant the sum of $1,500.00 together with legal rate of interest from October 11, 2011. Plaintiff shall pay this sum on or before October 1, 2012. IT IS FURTHER ORDERED AND DIRECTED that the Defendant shall serve a copy of this Order upon the Plaintiff. Family Law Clinic By the Court ~ ~ ~ , ~ ~ , rn' =- r ~x cn a , °.x ~ <~ a ' M. L. Ebert, Jr., J. zo ~ s rr~ C A ~ ~ ~; . -+ ~ ~ ~;« ..~ -- spy tea,,`/~d a~~~ia ?1.. 'y.i y! ( j „ F'R0 r d F?_., I 3?U Ii?A 231 12 OCT 15 PM 3: !? 5 THOMAS LEE THOMAS, SR., Plaintiff U3UM8LP,L; t40 GOU T p,; IN THE COURT OF COMIN"k CUMBERLAND COUNTY, PENNSYLVANIA V. CHERIESE THOMAS, Defendant NO. 09 - 7482 CIVIL TERM CIVIL ACTION - LAW PETITION TO WITHDRAW AS LEGAL COUNSEL AND NOW COMES the Petitioner, Jane Adams, Esquire, and files the above- referenced Petition and represents that: 1. Petitioner is Jane Adams, Esquire, an Attorney duly authorized to practice law in the Commonwealth of Pennsylvania, having a principal place of business located at 17 W. South St., Carlisle, Pa. 17013 2. Petitioner is currently attorney for Thomas Lee Thomas, Sr., Plaintiff in the above-captioned matter. 3. On August 30, 2012, Petitioner filed a Motion to Withdraw as legal counsel for Thomas Lee Thomas, Sr. 4. On August 30, 2012, a Rule to Show Cause was entered upon Plaintiff, returnable 20 days after service via regular mail upon Plaintiff. 5. On September 7, 2012, Counsel served Plaintiff via regular mail at the address prescribed in the Rule. A copy of the Certificate of Mailing is attached. 6. Over twenty (20) days have now elapsed since service of the Rule and Counsel has had no response from Plaintiff. 7. Counsel is requesting entry of the attached Order so that she may withdraw her appearance. 8. The Community Law Center, who is presenting Defendant, indicated; at the August 30, 2012 hearing regarding this matter that they did not oppose counsel's withdrawal. 9. This matter was previously assigned to Judge Ebert. WHEREFORE, Jane Adams, Esquire requests permission to withdraw her appearance for Thomas Lee Thomas, Sr. from the above-captioned matter. Respectfully Submitted, Date: to - 1 ?; ` / oP, Jjtb- dams, Esquire I. . 0.79465 7 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF THOMAS LEE THOMAS, SR. EXHIBIT A - CERTIFICATE OF SERVICE OF RULE TO SHOW CAUSE AND NOW, this October 15, 2012, I, Jane Adams, Attorney for Thomas Lee Thomas, Sr., hereby certify that a copy of the August 30, 2012 Motion to Withdraw as well as the Rule to Show cause was forwarded to Plaintiff by placing such in first-class mail, addressed to: Thomas Lee Thomas, Sr. certficata of Moiling 1361 Zimmerman Rd This Cetficate ofMeiligprovides evidence hat mail has beenpesentetl to USPS®tormeilmg il c a? . . This form may be used for domestic and international ma oc ,? Carlisle, Pa. 17013 From: [? ins T N PLAINTIFF i 1?0x-21 ^-_ TO: ` o N q C rn X, T ZJzr00 -4 •wm rn rn PS Form 3817, April 2007 PSN 7530-02-000-9065 Sub~, Adams, Esquire I . No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~~ ~~~~ ` ~ ~ J- ~ , ,rf.p "ii, .. , T~L.~ci~.~t~(t~ .~~4,~, , THOMAS LEE THOMAS, SR., Plaintiff V. CHERIESE THOMAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 7482 CIVIL TERM CIVIL ACTION -LAW ORDER OF COURT AND NOW, this 1 qth day of ~ ~"~ °~ t<~ , 2012, it is hereby ORDERED and DECREED that Jane Adams, Esquire, may withdraw her appearance on behalf of Thomas Lee Thomas, Sr., Plaintiff in the above-captioned matter. BY THE COURT: ^~ ~ _c cc: `Community Law Clinic ~/ Thomas Lee Thomas Jane Adams, Esquire ~~o~ e.S l~i,'l~ar l D/i9~ ~ ~~L THOMAS LEE THOMAS, IN THE COt7RT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA v. CIVIL ACTION -LAW IN DIVORCE CHERISE THOMAS, ~ =_ Dei-endant NO. 09-7482 CIVIL TERM ;~~'~~ ~~ :~, AFFIDAVIT OF SERVICE - ~,: -. 1, Autumn Brennan, hereby certify that I personally served a true and cor7•ect copy~'o'f the Order of Court, on Thomas Lee Thomas, by handing a copy of the Order to Thomas I.ee "Thomas at: - - ~ ~~ on the ~ ~ __th day of October 2012. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. 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: ;' ~ __, ~~ ~ Autumn Brennan THOMAS LEE THOMAS, SR., Plaintiff v. CHERiESE THOMAS, o>' ~x~ PR4TNOR~o~;aRY 2dl2 QCT 23 PM! 3= C 1 CU pENNSY VAN A 7Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - 7482 CIVIL TERM CIVIL ACTION -LAW Defendant PRAECIPE FOR WITHDRAWAL TO THE PROTHONOTARY: Pursuant to#f~e attached Order, please withdraw the appearance of Jane Adams, Esquire, as Attorney of record for Thomas Lee Thomas. Respectfully Submitted: Date: ~~ , a, C~ `~ ~, ~~ ne Adams, Esquire I. D o. 79465 W. South St. Carlisle, Pa. 17013 (717) 245-8508 THOMAS LEE THOMAS, SR., Plaintiff V. CHERIESE THOMAS, Defendant . ~' ~ ~ `' Ws _ ., , ~ W THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 7482 CIVIL TERM CIVIL ACTION -LAW ORDER OF COURT AND NOW, this e9 day of 0~~~'~e, ____, 2012, it is hereby ORDERED and DECREED that Jane Adams, Esquire, may withdraw her appearance on behalf of Thomas Lee Thomas, Sr., Plaintiff in the above-captioned matter. BY THE COURT: cc: Community Law Clinic Thomas Lee Thomas Jane Adams , Esquire TRUE CC?PY FRl°2~U1 ~r:~~;~~~°17 In Testimony whereof, ! hc:;~ a;~,~~s _.~~ ~,; han~1 and the seal of saki Court a~ C:;a ; ~> -a. This ~_ day of ~__ . _ ':' :.. _ /a ~~~~:~~y ~~~ Cheriese Thomas, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW IN DIVORCE c -�a Thomas Lee Thomas, Defendant/Respondent No. . 09-7482 CIVIL TERM =M : �D _ CD PETITION FOR WAGE ATTACHMENT UNDER 23 Pa.C.S.-A. §3502 - 1. Petitioner is Cheriese Thomas,residing at 1374 Grandview Court, Carlisle, PA -17013 2. Respondent is Thomas Lee Thomas, residing at 1361 Zimmerman Road, Carlisle,PA 17013. 3. On September 14, 2011 Petitioner and Respondent entered into a Marital Settlement Agreement resolving property issues. 4. The Marital Settlement Agreement was incorporated but not merged into the October.11, 2011 Divorce Decree. 5. Paragraph 2 of the Marital Settlement Agreement states "Husband shall pay Wife two hundred fifty ($250:00) dollars a month, by money order or in cash, for the next six (6) months, until the total amount that Husband has paid Wife is one thousand five hundred dollars ($1,500.00). Husband's monthly payment shall be due on the 1St day of each month and time is of the essence." 6. Paragraph 2 of the Marital Settlement Agreement further states "In the event that Husband is more than ten (10) days past due on any payment, the entire amount shall become immediately due and owing, and Wife shall be entitled to bring an action for contempt and/or to enforce against Husband for the entire amount, as well as interest." 7. On September 5, 2012 Respondent was found in civil contempt of the Marital Settlement Agreement for failure to make any payments to Petitioner and ordered to immediately pay Petitioner the sum of$1,500.00 together with legal rate of interest from October 11, 2011 on or before October 1, 2012. 8. As of July 11, 2013 Respondent has made no payment under the Marital Settlement Agreement or the September 5, 2012 Court Order. 9. Petitioner does not believe another contempt order will compel Respondent to pay the amount due to her. 10. Petitioner requests that this Court require payment be made by wage attachment. 11. An April 2011 Domestic Relations Order directs Respondent to pay Petitioner in child support the amount of$491.50 a month. 12. Petitioner believes and therefore avers that Respondent is employed. 13. In April 2011 Respondent's monthly net income was $2,233.00, according to Cumberland County Domestic Relations documents. 14. Respondent is unrepresented and the Community Law Clinic has not sought concurrence as required by C.C.R.P. 208.2(d). 15. Judge Ebert has previously ruled in this matter. WHEREFORE, Petitioner requests that: 1. Respondent immediately pay to Petitioner the sum of$1,500.00 with interest of$180.00 for a total of$1,680.00. 2. If Respondent is unable to immediately pay the sum of$1,680.00, his wages be attached for that purpose. Respectfully submitted, Date: JoKmathO Vega G Certj�d Legal Intern Megan i6esmeyer Supervising Attorney . THE COMMUNITY,LAW CLINIC 371 West South Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 241-3596 VERIFICATION I verify that the statements made in this.Petition 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. Cheriese Thomas Petitioner Cheriese Thomas, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner : OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION- LAW. IN DIVORCE Thomas Lee Thomas, : Defendant/Respondent No. 09-7482 CIVIL TERM CERTIFICATE OF SERVICE I, Johnathan Vega, hereby certify that I am serving a true and correct copy of the Petition for Wage Attachment under 23 Pa.C.S. § 3502(e)on Thomas Lee Thomas residing.at 1361 Zimmerman Road, Carlisle, PA 17013 by first class United States Mail. Date: �l 1 Johna han Vega G Certified,Legal Intern THE COMMUNITY LAW CLINIC 371 West South Street Carlisle, PA 17013 (717)243-2968 Fax: (717)241-3596 Cheriese Thomas, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW IN DIVORCE Thomas Lee Thomas, Defendant/Respondent No. 09-7482 CIVIL TERM Order of Court AND NOW,this 15*day of 2013, upon consideration of the foregoing petition, it is hereby ordered that: 1. A Rule is issued upon Defendant, Thomas Lee Thomas,to show cause why the relief requested by Plaintiff should not be granted; 2. Defendant shall file an answer to the petition within 216 days of this date. 3. The petition shall be decided under PA.R.C.P. No. 206.7; 4. Argument shall be held on_ �`� , 2013 in Courtroom a�— of the Cumberland County Courthouse; and 5. Notice of the entry of this order shall be provided to all parties by the petitioner. BY THE COURT J. CC: mmunity Law Clinic, for Plaintiff Thomas Lee Thomas,pro se c -y Zn XCn 7z > iz F Cheriese Thomas, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Thomas-Lee Thomas, Defendant NO. 09 - 7482 CIVIL TERM 'rn, Mcy CERTIFICATE OF SERVICE oo n I, Johnathan Vega, Certified Legal Intern, Community Law Clinic, here@Rrti th h served a true and correct copy of the July 15 Order issuing a Rule to show cause o as L e, Thomas, residing at 71 East Willow St, Carlisle, PA 17013, by depositing a copy of the same'in the United States mail on the 17`h day of July 2013. Ja�han Vega ertified Legal Interne : i COMMUNITY LAW CLINIC 371 West South Street Carlisle, PA 17013 (717)243-2968 Fax: (717) 241-3539 i COMMONWEALTH OF PENNSYLVANIA ) SS: OCA: COUNTY OF CUMBERLAND ) TO: Ronny R. Anderson, Sheriff, or any duly authorized law enforcement officer. RE: THOMAS LEE THOMAS DOCKET #: 09-7482 CIVIL rte, 71 East Willow Street Carlisle, PA 17013 rn� - rn rr DOB: 10/17/1985 SEX: M RACE: Black - � `'� —'� HT: 70 WT: EYES: BRO HAIR: BLK SSN: �`' asp} FBI: OLN: 27920159 SID: Zr WHEREAS, the above-named defendant failed to appear for a hearing scheduled for August 27, 2013, at 3:00 p.m. WHEREAS, this Court on August 27, 2013, directed a Bench Warrant be issued for the apprehension of the defendant. This is therefore to command you to arrest the defendant above. It is specifically ordered that the Sheriff of Cumberland County shall only serve this warrant on a weekday between the hours of 8:30 a.m. and 3:00 p.m. and shall bring Defendant immediately before the Court for the purposes of posting security and setting a final hearing on the issue of setting a wage attachment. WITNESS the undersigned Judge, at Carlisle, this 27th day of August, 2013. M. L. Ebert, Jr., J. ATTEST: CLERK OF COURT (SEAL) Cony Iv aCe_tf—'r Driver Detail Page 1 of 4 •J Driver Detail PA Department of Transportation river Demographics Source: PennDOT IM THOMAS, THOMAS 27 920 159 10/17/1985 LEE Driver License Number Date of Birth Driver Name M 70 (BR) BROWN Gender Height (inches) Eye Color 71 E WILLOW ST YES Emergency Contact CARLISLE, PA 17013 Organ Donor Driver History Information Address (View Map) Driver License Source: PennDOT IM 12/16/201.1 10/18/201.5 00 (C) SINGLE VEH<= 26,000. Issue Date Expiration Date Duplicate Count License Class (1) Revoked, Suspended, Endorsements Restrictions Commercial Cancelled, or Recalled. Restrictions Suspension Information (OI) REG LIC/1D. CDL Medical CDL Downgraded CDL Medical Self Record Type Certificate Status Date Certification Photo History Source: Viisage Corporation Photo Repository Photo Record(1 of 6) Photo Capture Station Information 08/20/2013 11:53:41 (021) CARLISLEs s_ Photo Date Location rastahl 01 2013021.01 @232033 Operator ID Station ID Viisage Control ID �. Driver Information - 27920159 10/17/1985 � Driver License Number Date of Birth CUMBERLAND County ; ,. ID ONLY NOT A LICENSE License Card Type Photo Record(2 of 6) Photo Capture Station Information. 12/16/2011 10:21:49 (022) HARRISBURG(ROC) Photo Date Location https://www.jnet.state.pa.us/DriverInfoWebApp/DriverInfoProcessControl 8/26/2013 CHERIESE THOMAS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS NO. 09-7482 CIVIL TERM THOMAS LEE THOMAS, CIVIL ACTION - LAW Defendant IN DIVORCE IN RE: RULE TO SHOW CAUSE; BENCH WARRANT ORDER OF COURT AND NOW, this 27th day of August, 2013, this being the time and place set for hearing on Plaintiff' s Petition For Wage Attachment and the Court noting that the Plaintiff has appeared and is ready to proceed and that the Defendant, Thomas Lee Thomas, was served with a copy of this Court ' s order and the Court notes that the Defendant has violated the order in the sense he has failed to file an answer as required and has not appeared here this date, accordingly, IT IS HEREBY ORDERED AND DIRECTED that a rule is issued to show cause why he should not be held in contempt and a bench warrant shall be issued for his arrest. By the Court, M.L. Eb rt, 'Jr. , J. ., Joh- nathan Vega, CLI Megan Riesmeyer, Esquire For the Plaintiff homas Lee Thomas C= = --�171 East Willow Street Mqu Carlisle, PA 17013 ;rm M Sheriff :mlc :z CD C:: :z c-n L.L 49 a CHERIESE THOMAS, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW : IN DIVORCE THOMAS LEE THOMAS, Defendant/Respondent : 09-7482 CIVIL TERM IN RE: BENCH WARRANT VACATED ORDER OF COURT AND NOW, this 16th day of September, 2013, the defendant having been apprehended on a bench warrant regarding a Rule to Show Cause why he should not be held in contempt, IT IS HEREBY ORDERED AND DIRECTED that the defendant shall appear for hearing in this matter on September 25, 2013, at 3 : 30 p.m. , in Courtroom Number 2 . The defendant will be released on his own recognizance . The defendant is directed to advise the court should he change his address . By the Court, M. L. Ebert, Jr. , Megan Riesmeyer, Esquire Penn State Dickinson Law Clinic 1' For the Plaintiff rnw M M-- homas Lee Thomas "t° po _-a� 71 East Willow St . ' - Carlisle, Pa. 17013 Y' :mt f Iy —j cn ies ' r o 9 acill 3 COMMONWEALTH OF PENNSYLVANIA In the Court of Common Pleas Vs. Cumberland County, Pennsylvania THOMAS LEE THOMAS CIVIL- 7482-2009 I, Shannon Shertzer, Deputy Sheriff, being duly sworn according to law state that on September 16, 2013 the above named defendant was arrested at the Cumberland County Courthouse in Domestic Relations Support Court and taken into custody to appear before Judge Ebert. Sheriff Cost: $ 0 . 00 So answers, Ronny R. Anderson, Sheriff gy _ . (� g Shannon Shertzer, Deputy Fri c Cr) CHERIESE THOMAS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA • V : 09-7482 CIVIL TERM THOMAS LEE THOMAS, SR . , • Defendant . IN RE: CONTEMPT ORDER OF COURT AND NOW, this 25th day of September, 2013, upon consideration of Cheriese Thomas ' s petition for wage attachment, and after hearing in the matter, IT IS HEREBY ORDERED AND DIRECTED that the defendant ' s wages at Ritner Steel located at 131 Stover Drive, Carlisle, Pennsylvania, will be attached for the amount of $50 . 00 for each month until the sum of $1, 500 . 00 is paid. By the Court, I()M. NI,t, . , J. /ohnathan Vega, Certified Legal Intern 3 Thomas Place, Esquire c., The Community Law Clinic - -- For the Plaintiff/Petitioner homas Lee Thomas, Sr. _ ;' 1361 Zimmerman Rd. .cam —le-, Carlisle, Pa . 17013 '� mac- _ co-7-CD :mtf J ^ /� 5 no 0,.(7-