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Home My WebLink About09-8221 ABOM ?' ICuTUr_nicis Wavne Helnick, Esquire AttornevLD. No.: 53150 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 MARY LYNN BLYSTRA Plaintiff V. ANDREW RICHARD BLYSTRA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09- P-4 Ctvi17EM PRAECIPE TO THE PROTHONOTARY: Enter judgment against the Defendant in the amount of $46,919.00, in accordance with the attached certified copy of judgment and docket entries in the Court of Allegan County, Michigan and Enforcement of Foreign Judgment Affidavit. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. Wayne Mfelnick 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiffs CT OS D FOJ by 904 -DO JUDGE CRONIN ALLEGAN COUNTY CASE REGISTER OF ACTIONS 10/25/09 PAGE 1 FILE 02/08/06 ADJ DT 11/28/06 CLOSE 11/28/06 SCAO:SEC D LINE 02 P 001 BLYSTRA,MARY,LYNN VS D 001 BLYSTRA,ANDREW,RICHARD 245 STANDISH ST L/K/A 245 STANDISH ST VACANT HOLLAND MI 49423 HOLLAND MI 49423 SS# XXXXXXXXX SS# XXXXXXXXX ATY:MIMS,MARY M., ATY:HUGHES,JOSEPH S P-30222 616-396-1265 P-52832 269-473-2370 DISPOSITION 11/28/06 DVG PCH SERVICE/ANS 02/22/06 ANS Actions, Judgments, Case Notes Num Date Judge Chg/Pty Event Description/Comments ---- 1 -------- -------- 02/08/06 BEACH -- ------- ---------------------------------- SUMMONS AND COMPLAINT --- ----- CLK --- LAC RECEIPT# 00058412 AMT $150.00 VERIFIED COMPLAINT FOR CLK SEPARATE MAINTENANCE CLK RECORD OF DIVORCE OR ANNULMENT CLK 2 02/12/06 ORDER RE: ASSETS CLK RMN 8 02/16/06 D 001 RETURN OF SERVICE CLK RMN 3 02/21/06 PROOF OF SERVICE FILED CLK LKP 4 02/22/06 PROOF OF SERVICE FILED CLK LKP 5 D 001 ANSWER FILED CLK LKP 6 D 001 APPEARANCE CLK LKP ATTORNEY: P-24143 THOMAS CLK 7 02/24/06 SET NEXT DATE FOR: 03/10/06 2:00 PM CLK CAW PRE-TRIAL HEARING HON. HARRY A. BEACH 9 NOTICE OF PRE-TRIAL CONFERENCE CLK LAC DOMESTIC MATTER W/CERTIFICATE CLK OF MAILING CLK 10 03/01/06 PROOF OF SERVICE CLK DLP 11 03/14/06 PRE-TRIAL STATEMENT RETURNED CLK RMN 12 03/29/06 COUNTERCLAIM FOR DIVORCE CLK RMN 13 PROOF OF MAILING CLK RMN 14 03/30/06 SET NEXT DATE FOR: 09/28/06 1:00 PM CLK CAW TRIAL HON. HARRY A. BEACH (BACK UP)(1/2 DAY NON-JURY CLK TRIAL) CLK 15 SET NEXT DATE FOR: 10/26/06 1:00 PM CLK CAW TRIAL HON. HARRY A. BEACH (BACK UP)(1/2 DAY NON-JURY CLK TRIAL) CLK 16 SET NEXT DATE FOR: 11/28/06 1:00 PM CLK CSB TRIAL HON. HARRY A. BEACH (1/2 DAY NON-JURY TRIAL) CLK (SETTLED - TO PUT PRO CON ON) CLK 17 03/31/06 NOTICE OF TRIAL CLK JRC 18 06/08/06 SET NEXT DATE FOR: 07/14/06 9:00 AM CLK CAW MOTION HEARING HON. HARRY A. BEACH (COMPEL) CLK 1 CT?OS F.D FQJ CASE REGISTER OF ACTIONS 10/25/09 PAGE 2 Ot;-O'390415-DO JUDGE ---- --------------- CRONIN FILE 02/08/06 ADJ DT 11/28/06 CLOSE ---- 11/2 8/06 19 06/13/06 ----------------------------------------------- PLAINTIFF'S MOTION TO COMPEL ----- CLK ---- LKP ANSWERS TO INTERROGATORIES CLK 20 NOTICE OF HEARING CLK LKP 21 PROOF OF SERVICE FILED CLK LKP 22 MOTION FILED CLK DLP RECEIPT# 00061225 AMT $20.00 23 07/17/06 STIPULATION AND ORDER CLK RMN 24 07/24/06 PROOF OF SERVICE FILED CLK DLP 25 08/18/06 SET NEXT DATE FOR: 09/15/06 9:00 AM CLK CAW MOTION HEARING HON. HARRY A. BEACH (COMPEL/WITHDRAW/DEFAULT) CLK 26 08/21/06 RE-NOTICE OF HEARING CLK RMN 27 PROOF OF SERVICE CLK RMN 28 08/24/06 MOTION FILED CLK LKP RECEIPT# 00062827 AMT $20.00 29 NOTICE OF HEARING CLK RMN 30 MOTION SEEKING PERMISSION TO CLK RMN WITHDRAW CLK 31 PROOF OF MAILING CLK RMN 32 08/31/06 AMENDED COMPLAINT FOR ABSOLUTE CLK LKP DIVORCE CLK 33 PROOF OF SERVICE FILED CLK LKP 34 09/05/06 PLAINTIFF'S MOTION TO DEFAULT CLK LKP DEFENDANT FOR FAILURE TO CLK COMPLY WITH DISCOVERY CLK NOTICE OF HEARING CLK 35 MOTION FILED CLK DLP RECEIPT# 00063064 AMT $20.00 36 09/15/06 ORDER ALLOWING WITHDRAWAL CLK LKP 37 D 001 FROM: THOMAS,JOHN M., CLK LKP TO: PRO-PER CLK 38 MOTION HEARING CRT RMN PLAINTIFF PRESENT WITH COUNSEL CRT DEFENDANT'S COUNSEL PRESENT CRT ON DEFENDANT'S COUNSELS MOTION CRT TO WITHDRAW. ARGUMENT HEARD. CRT MOTION GRANTED. PLAINTIFF CRT COUNSEL MOTIONED TO ENTER CRT DEFAULT. MOTION GRANTED. CRT DEFAULT TO ENTER. CRT 39 09/21/06 PROOF OF SERVICE CLK JLP 40 09/22/06 NOTICE OF SUBMISSION OF ORDER CLK LKP ENTERED UNDER THE 7 DAY RULE CLK PROOF OF SERVICE CLK 41 PROOF OF MAILING CLK RMN 42 09/26/06 SUBPOENA WITH PROOF OF SERVICE CLK LAC 43 10/03/06 ORDER CLK JLP AFFIDAVIT; NON-MILITARY CLK AFFIDAVIT; AND DEFAULT CLK 44 10/16/06 PROOF OF SERVICE FILED CLK LKP 45 11/17/06 REQUEST FOR DEFAULT JUDGMENT CLK RMN 46 NOTICE OF REQUEST FOR CLK RMN JUDGMENT CLK 47 PROOF OF SERVICE CLK RMN 48 11/28/06 D 001 PRO-CONFESSO HEARING CRT JLP DIVORCE GRANTED CRT CLOS I?D FOJ CASE REGISTER OF ACTIONS 10/25/09 PAGE 3 '06-0 ---- 39045-DO JUDGE ---------------- CRONIN FILE 02/08/06 ADJ DT 11/28/06 CLOSE -------------------- 11/28/06 ------------------------------- LOG: PLAINTIFF PRESENT WITH ----- CRT ---- ATTORNEY ON DATE AND TIME SET CRT FOR TRIAL. TESTIMONY HEARD. CRT DIVORCE GRANTED. JUDGEMENT CRT MAY ENTER. CRT 49 FINAL ORDER OR JUDGMENT FILED CLK RMN DEFAULT JUDGMENT OF DIVORCE CLK 50 12/04/06 CLERK'S NOTICE CLK RMN 51 PROOF OF SERVICE FILED CLK LKP 52 12/13/06 PROOF OF SERVICE FILED CLK LKP (CERTIFIED MAIL) CLK 53 PROOF OF SERVICE FILED CLK LKP (CERTIFIED MAIL) CLK 54 02/16/07 MOTION FILED CLK RMN RECEIPT# 00066622 AMT $20.00 55 D 001 APPEARANCE CLK RMN ATTORNEY: P-17353 MCCUNE CLK 56 MOTION FOR RELIEF FROM CLK RMN JUDGMENT ORDER AND/OR SET CLK ASIDE DEFAULT JUDGMENT CLK 57 PROOF OF SERVICE BY MAIL CLK RMN 58 02/20/07 SET NEXT DATE FOR: 04/13/07 2:00 PM CLK CAW MOTION HEARING HON. ROBERT A. BENSON (RELIEF FROM JUDGMENT) CLK 59 02/22/07 REMOVE NEXT EVENT: 04/13/07 2:00 PM CLK CAW MOTION HEARING HON. ROBERT A. BENSON 60 SET NEXT DATE FOR: 04/20/07 2:00 PM CLK CSB MOTION HEARING HON. GEORGE R. CORSIGLIA (RELIEF FROM JUDGMENT/OBJECT) CLK 61 02/23/07 NOTICE OF HEARING CLK LAC PROOF OF SERVICE CLK 62 02/26/07 NOTICE OF SUBMISSION OF ORDER CLK LKP ENTERED UNDER THE 7 DAY RULE CLK PROOF OF SERVICE CLK (Plaintiff, in advance, paid CLK for a Certified Copy of CLK proposed order. Objection was CLK filed 3-2-07. When Order is CLK signed please certify copy.) CLK 65 03/02/07 DEFENDANT'S OBJECTION TO ENTRY CLK LKP OF QUALIFIED DOMESTIC CLK RELATIONS ORDER CLK NOTICE OF HEARING CLK PROOF OF SERVICE CLK 63 03/06/07 TRANSCRIPT/HONORABLE HARRY A CLK RMN BEACH JUDGE-PRO CON-NOVEMBER CLK 28, 2006 CLK 64 03/07/07 CLERK'S NOTICE CLK RMN 66 03/21/07 TRANSCRIPT/HONORABLE HARRY A CLK RMN BEACH JUDGE-MOTION HEARING- CLK SEPTEMBER 5, 2006 CLK 67 03/22/07 CLERK'S NOTICE CLK RMN 68 D 001 FROM: MCCUNE,DENNIS S., CLK RMN TO: THOMAS,JOHN M., CLK C OS'?:T., FQJ ' CASE REGISTER OF ACTIONS 10/25/ 09 PAGE 4 06-0:3:)04 5-DO JUDGE-CRONIN-- FILE 02/08/06 ADJ DT 11/28/06 CLO SE 11/2 8/06 69 03/23/07 ------ ------------------------------ PLAINTIFF'S RESPONSE TO --- ----- CLK ---- RMN DEFENDANT'S MOTION FOR RELIEF CLK FROM JUDGMENT ORDER AND/OR SET CLK ASIDE DEFAULT JUDGMENT CLK 70 71 03/30/07 PROOF OF SERVICE CLK RMN SET NEXT DATE FOR: 05/25/07 2:00 PM CLK CSB MOTION HEARING HON. GEORGE R. CORSIGLIA (SET ASIDE JUDGMENT/OBJ QDRO) CLK 72 04/09/07 REMOVE NEXT EVENT: 04/20/07 2:00 PM CLK CAW MOTION HEARING HON. GEORGE R. CORSIGLIA 73 05/01/07 PROOF OF SERVICE FILED CLK LKP 74 NOTICE OF HEARING CLK LKP 75 05/16/07 SET NEXT DATE FOR: 05/18/07 11:30 AM CLK CSB MISCELLANOUS HEARING HON. WILLIAM A. BAILLARGEON (TELEPHONE CONFERENCE 76 05/18/07 REMOVE NEXT EVENT: 05/25/07 2:00 PM CLK CSB MOTION HEARING HON. GEORGE R. CORSIGLIA 77 SET NEXT DATE FOR: 05/30/07 3:00 PM CLK CSB MOTION HEARING HON. WILLIAM A. BAILLARGEON (SET ASIDE & OBJECTION TO QDRO CLK 78 05/21/07 NOTICE OF HEARING CLK LKP 79 05/23/07 MEMORANDUM OF LAW IN SUPPORT CLK JLB OF DEFENDANTS MOTION FOR CLK RELIEF OF JUDGMENT CLK 80 05/29/07 PLAINTIFF'S MEMORANDUM OF LAW CLK LAC IN OPPOSITION TO DEFENDANT'S CLK MOTION FOR RELIEF FROM CLK JUDGMENT CLK 81 05/30/07 SET NEXT DATE FOR: 06/07/07 3:00 PM CLK CSB MOTION HEARING HON. WILLIAM A. BAILLARGEON (CONTINUATION OF SET ASIDE/ CLK OBJECTION TO QDRO) CLK 82 MOTION HEARING CRT JLP LOG: PARTIES PRESENT WITH CRT COUNSEL ON MOTION TO SET CRT ASIDE DEFAULT AND OBJECTION CRT TO QDRO. MATTER ADJOURNED CRT DEFENDANT TO PAY ATTORNEY FEES CRT IN THE AMOUNT OF $1000 TO CRT PLAINTIFF. IF DEFENDANT DOES CRT NOT APPEAR AT NEXT HEARING CRT MOTION WILL BE DENIED FORTH- CRT WITH AND CASE WILL BE CRT 83 06/05/07 CONCLUDED. CRT NOTICE OF SUBMISSION OF ORDER CLK LKP ENTERED UNDER THE 7 DAY RULE CLK 84 06/14/07 PROOF OF SERVICE CLK 85 06/21/07 ORDER PROOF OF SERVICE FILED CLK DLP CLK JLB 86 NOTICE OF SUBMISSION OF ORDER CLK LKP ENTERED UNDER THE 7 DAY RULE CLK CLOSED FOJ CASE REGISTER OF ACTIONS 10/25/09 PAGE 5 06-039045-DO JUDGE CRONIN FILE 02/08/06 ADJ DT 11/28/06 CLOSE -- - - :11/28/06 -------- ----- --------------------- -------------------------------------- - -- PROOF OF SERVICE CLK 87 06/29/07 QUALIFIED DOMESTIC RELATIONS CLK LKP ORDER CLK 88 07/02/07 NOTICE OF SUBMISSION OF ORDER CLK LKP ENTERED UNDER THE 7 DAY RULE CLK PROOF OF SERVICE CLK 89 07/12/07 AMENDMENT TO JUDGMENT OF CLK LAC DIVORCE CLK 90 07/13/07 PROOF OF SERVICE FILED CLK LKP 91 07/19/07 PROOF OF SERVICE FILED CLK LAC 92 01/04/08 PROOF OF SERVICE FILED CLK LKP (CERTIFIED MAIL) CLK 93 02/04/08 SUBPOENA/ORDER TO APPEAR AND/ CLK LAC OR PRODUCE CLK 94 PROOF OF SERVICE FILED CLK LAC 95 02/11/08 SET NEXT DATE FOR: 03/21/08 9:00 AM CLK CAW MOTION HEARING HON. WILLIAM A. BAILLARGEON (SHOW CAUSE) CLK 96 02/14/08 P 001 MOTION FILED CLK JLB RECEIPT# 00073755 AMT $20.00 97 PLAINTIFFS MOTION FOR CLK DLP REIMBURSEMENT OF FUNDS FROM CLK DEFENDANT AND FOR AN ORDER TO CLK SHOW CAUSE TO HOLD DEFENDANT CLK IN CONTEMPT CLK PROOF OF SERVICE CLK 98 NOTICE OF SUBMISSION OF ORDER CLK LKP ENTERED UNDER THE 7 DAY RULE CLK PROOF OF SERVICE CLK 99 02/15/08 ORDER TO SHOW CAUSE CLK DLP 100 02/20/08 FIRST AMENDED QUALFIED CLK JLB DOMESTIC RELATIONS ORDER CLK 101 02/26/08 PROOF OF SERVICE FILED CLK LKP 102 03/18/08 BAILLARGEO CASE REASSIGNMENT CLK CSB FROM: BEACH,HARRY A., CLK TO: BAILLARGEON,WILLIAM A., CLK 103 03/19/08 PROOF OF SERVICE FILED CLK JLB 104 03/21/08 ORDER OF CONTEMPT AND OTHER CLK JLB RELIEF CLK UNIFORM SPOUSAL SUPPORT ORDER CLK ORDER REGARDING INCOME CLK WITHHOLDING CLK 105 MOTION HEARING CRT LAC PLAINTIFF PRESENT WITH COUNSEL CRT FOR MOTION TO SHOW CAUSE CRT DEFENDANT. MOTION GRANTED CRT ORDERS TO ENTER CRT 106 03/25/08 AFFIDAVIT OF SERVICE CLK LKP 107 PROOF OF SERVICE FILED CLK LKP 108 04/22/08 ORDER/NOTICE TO WITHHOLD INCOME CLK LKP FOR CHILD SUPPORT CLK 109 05/06/08 PROOF OF SERVICE FILED CLK LKP (CERTIFIED MAIL) CLK 110 05/12/08 SET NEXT DATE FOR: 06/13/08 9:00 AM CLK CAW MOTION HEARING HON. WILLIAM A. BAILLARGEON C OS^^ FQJ 06-0`90 1 CASE REGISTER OF ACTIONS 10/25/09 PAGE 6 4 5-DO JUDGE CRONIN------- --- -FILE -02/08/06 ADJ DT 11/28/06 CLOSE ------ 11/2 8/06 -------------------------- (ENFORCE JUDGMENT,SET SPOUSAL ----- CLK ---- SUPPORT,INSTRUCT FOC ON CLK WITHHOLDING ORDER) CLK 111 05/16/08 P 001 MOTION FILED CLK LAC RECEIPT# 00075635 AMT $20.00 112 PLAINTIFF'S MOTION TO ENFORCE CLK DLP JUDGMENT OF DIVORCE AND TO CLK SET ADDITIONAL SPOUSAL SUPPORT CLK NOTICE OF HEARING CLK 113 05/20/08 ORDER/NOTICE TO WITHHOLD INCOME CLK JLB FOR CHILD SUPPORT CLK 114 05/27/08 PLAINTIFF'S MOTION TO INSTRUCT CLK LKP THE FRIEND OF THE COURT TO CLK COMPLY WITH ORDER REGARDING CLK INCOME WITHHOLDING DATED CLK 3-21-08 CLK NOTICE OF HEARING CLK 115 P 001 MOTION FILED CLK LAC RECEIPT# 00075788 AMT $20.00 116 06/11/08 PROOF OF SERVICE FILED CLK LKP 117 PLAINTIFF'S ANSWER TO CLK LKP DEFENDANT'S RESPONSE TO MOTION CLK FOR SUPPORT CLK 118 D 001 APPEARANCE CLK LKP ATTORNEY: P-52832 HUGHES CLK 119 D 001 FROM: THOMAS,JOHN M., CLK LKP TO: HUGHES,JOSEPH S., CLK 120 PROOF OF SERVICE FILED CLK LKP 121 DEFENDANT'S RESPONSE TO MOTION CLK LKP FOR SUPPORT CLK 122 06/13/08 MOTION HEARING CRT DLP PARTIES REPRESENTED BY COUNSEL CRT FOR PLAINTIFF'S MOTION TO CRT ENFORCE JUDGMENT AND FOR CRT MODIFICATION OF SPOUSAL CRT SUPPORT. MOTION GRANTED WITH CRT EXCEPTION OF FOC INVOLVEMENT. CRT 123 06/23/08 NOTICE OF SUBMISSION OF ORDER CLK LKP ENTERED UNDER THE 7 DAY RULE CLK PROOF OF SERVICE CLK 124 07/02/08 P 001 ORDER AFTER HEARING CLK LAC 125 07/10/08 PROOF OF SERVICE FILED CLK LKP 126 07/25/08 AFFIDAVIT OF PERSONAL SERVICE CLK LKP 127 08/21/08 REQUEST & WRIT FOR GARNISHMENT CLK DLP (PERIODIC) GANNETT FLEMING CLK EXP 11-19-2008 CLK 128 P 001 WRIT OF GARNISHMENT,ATTACHMENT,EXEC CLK JLB UTION/JUDGMENT DEBTOR DISCOV.SUBP. CLK RECEIPT# 00077527 AMT $15.00 129 09/10/08 PROOF OF SERVICE FILED CLK LKP (CERTIFIED MAIL) CLK 130 11/10/08 P 001 MOTION FILED CLK KAS RECEIPT# 00079135 AMT $20.00 131 MOTION FILED CLK JLP RECEIPT# 00079136 AMT $20.00- 132 12/08/08 PROOF OF SERVICE FILED CLK DLP 133 01/16/09 SET NEXT DATE FOR: 01/30/09 9:00 AM CLK CAW CLOSED FOJ CASE 0 REGISTER OF ACTIONS 10/25/09 PAGE 7 6-0 39045-DO JUDGE CRONIN --- FILE 02/08/06 ADJ DT 11/28/06 CLOSE ----------------------------- 11/2 8/06 --------- MOTION HEARING ----- ---- (CORRECT ORDER) CLK 134 01/22/09 P 001 MOTION FILED CLK JLB RECEIPT# 00080343 AMT $20.00 135 PROOF OF SERVICE FILED CLK JLP 136 P 001 PLAINTIFFS MOTION TO CORRECT CLK JLP ORDER CLK NOTICE OF HEARING CLK 137 01/27/09 CRONIN CASE REASSIGNMENT CLK CSB FROM: BAILLARGEON,WILLIAM A., CLK TO: CRONIN,KEVIN W., CLK 138 01/30/09 AMENDED ORDER OF CONTEMPT AND CLK JLC OTHER RELIEF CLK 139 MOTION HEARING CRT DLP PLAINTIFF COUNSEL PRESENT FOR CRT MOTION TO CORRECT CLERICAL CRT ERROR IN ORDER REGARDING MONEY CRT JUDGMENT. DEFENDANT FAILED TO CRT APPEAR. AMENDED ORDER ENTERED. CRT 140 02/06/09 PROOF OF SERVICE FILED CLK JLB .... .......................... END OF SUMMARY ...................... ..... ... I do hereby certify that attached hereto are copies of the original papers pertaining to the above entitled matter. Dated at Allegan, Michigan this 23rd day of October 2009. ie Porter, Deputy Court Clerk STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF ALLEGAN MARY LYNN BLYSTRA, Plaintiff, V. ANDREW RICHARD BLYSTRA, Defendant. CASE NO. 06-39045-DO HON. WILLIAM A. BAILLARGEON Mary M. Mims (P30222) Attorney for Plaintiff SCHOLTEN AND FANT 246 River Avenue, Suite 100 P.O. Box 9008 Holland, MI 49423 Telephone: (616) 396-1265 Joseph S. Hughes (P52832) Attorney for Defendant P.O. Box 83 Berrien Springs, MI 49103 Telephone: (269) 473-2370 ORDER AFTER HEARING At a session of said Court in the City of Allegan, County of Allegan, d State of Michigan on the day of , 2008. PRESENT: WILLIAM . BAILLARGEON THIS MATTER having come on for hearing on June 13, 2008 on the Motions of the Plaintiff, a hearing having been held and the Court having given its opinion on that day; a IT IS HEREBY ORDERED AS ADJUDGED as follows: 1. Mary Blystra shall have a non-dischargeable Judgment against Defendant Andrew Blystra in the amount of $46,919 together with interest at the judgment rate for past due spousal support obligations under the terms of the Judgment of Divorce. That amount consists of the following: a. $33,652 in payments relating to the former marital home which Plaintiff was called upon to pay. b. $11,445 in attorney fees which Defendant was ordered to pay and failed to do. C. $1,822 in cash value of life insurance which Defendant took which was awarded to Plaintiff. 2. This obligation is for spousal support and is not dischargeable. Plaintiff may pursue all remedies available to creditors including but not limited to garnishment to enforce this judgment. 3. Defendant, Andrew Blystra shall immediately reinstate Plaintiff as the sole beneficiary of his MET life policy no. 832 985 256 UL and shall provide proof forthwith that he has done so. 4. This is in addition to all sums which the Plaintiff has previously been awarded for additional arrearages under the judgment. WILLMA 6W? ?oN Hon. William A. Baillargeon Circuit Court Judge 2 Jr"S-V 0'?-Ta GOpA ,A 0 CLERIC FEB 0 9 2009 WO5CNYLJM AMAWIVV STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF ALLEGAN 113 Chestnut, Allegan, MI 49010 (269) 673-0300 MARY LYNN BLYSTRA, Plaintiff, V. ANDREW RICHARD BLYSTRA, CASE NO. 06-39045-DO HON. WILLIAM A. BAILLARGEON ORDER OF CONTEMPT AND OTHER RELIEF Defendant. Mary M. Mims (P30222) Attorneys for Plaintiff SCHOLTEN FANT Andrew Richard Blystra, Defendant In Pro Per 3005 Market Street 246 S. River Avenue, Suite 100 Camp Hill, PA 17011 Holland, MI 49422-9008 (616) 396-1265 At a session of said Court held in the Courthouse in the City of Allegan, County of Allegan, and State of Michigan, on this 24 day of AM rOh , 2008. PRESENT: HONORABLE WILLIAM A. BAILLARGEON Circuit Court Judge THIS MATTER having come on for hearing on March 21, 2008, on a petition and order to show cause against the Defendant, Andrew Richard Blystra; Defendant having been personally served on March 7, 2008; The Court having read the Verified Motion of the Plaintiff, and being otherwise fully advised in the Premises; IT IS ORDERED AND ADJUDGED as follows: The Defendant, Andrew Richard Blystra, is found in contempt of this Court for his violation of the terms of the Judgment of Divorce. 2. Defendant shall pay to Plaintiff $19,800 which represents funds withdrawn after entry of the Judgment from the TIAA/CREF account which was awarded to the Plaintiff. 3. Plaintiff shall have a money Judgment against Plaintiff in that amount and shall be - . • • f allowed to collect it pursuant to all legal enforcement methods allowable by law, including garnishment or withholding from Defendant's income. 4. An Order of Income Withholding shall enter allowing $19,800 to be collected from Defendant's employer. A Uniform Spousal Support Order is attached hereto. 5. Defendant shall reimburse Plaintiff $ in attorney fees in connection with this Motion. VULUAMA, 66AAARGEON Hon. William A. Baillargeon Circuit Court Judge r .990 D -PITY Co_G-aK*9-- 2 Appr&:,ed, SCAO • STATE OF MICHIGAN 48TH JUDICIAL CIRCUIT ALLEGAN COUNTY Court address 113 Chestnut Street, Allegan, MI 49010 Original - Court 1 st copy - Plaintiff UNIFORM SPOUSAL SUPPORT ORDER (PAGE 1) 17 MODIFICATION Plaintiffs name, address; and telephone no. Mary Lynn Blystra 245 Standish Holland, MI 49423 Plaintiffs attorney name; address; telephone no., and bar no. Mary M. Mims (P30222) 246 S. River Avenue, Suite 100 Holland, MI 49423 (616) 396-1265 Plaintiffs source of income name, address, and telephone no. 1. v 2nd copy - Defendant 3rd copy - Friend of the Court CASE NO. 06-39045-DO FAX no. Court telephone no. (269) 673-0300 Defendant's name, address, and telephone no. Andrew Richard Blystra 3005 Market Street Camp Hill, PA 17011 Defendant's atttorney name, address, telephone no., and bar no. ' In Pro Per Defendant's source of income name, address, and telephone no. Gannett Fleming 209 Senate Avenue Camp Hill PA 17011 (717) 763-7211 Spousal support in the amount of $ shall be paid through the Michigan State Disbursement Unit and paid to the payee. Payments payable to a third parry that must be paid directly to, or for the benefit of, the third party are listed below. If an amount is payable to the payee for a particular type of expense, the payee shall make the payment for that expense and hold the payer harmless for any liability the payer may incur due to the payee's failure to pay the expense. Type Amount Pa to Mary Lynn Blystra Total 'pousal Support. Spousal support shall be paid monthly as follows: Payer: Payee: Effective )ate: Andrew Richard Blystra Mary Lynn Blystra 42-1 dg, T (see Page 2 for remainder of order) FOC 10b (5/07) UNIFORM SPOUSAL SUPPORT ORDER, PAGE 1 MCL 552.13. MCR 3.211 Approvgd, SCikO STATE OF MICHIGAN 48TH JUDICIAL CIRCUIT ALLEGAN COUNTY Court address Date 113 Chestnut Street, Allegan, MI 49010 -- ._._.._._......----._._..._.....--- - _.... _..---. ---- ---- - ------ -- --- - ---- Plaintiffs n. ame Mary Lynn Blystra v 0 FAX no. Court telephone no. (269) 673-0300 Defendant's name - ----- Andrew Richard Blystra e 2. Income withholding takes immediate effect for those items payable through the Michigan State Disbursement Unit. 3. This order continues until the following events: [- Other (specify all other events) Original - Court 1 st copy - Plaintiff UNIFORM SPOUSAL SUPPORT ORDER (PAGE 2) 2nd copy - Defendant 3rd copy - Friend of the Court CASE NO. 06-39045-DO $-L ,800.00 is paid. 1- Death of the payee. E 4. For tax purposes, the payments will be deductible to the payer and included in the income of the payee. 5. Retroactive Modification, Surcharge for Past Due Support, and Liens for Unpaid Support. Support is a judgment the date it is due and is not retroactively modifiable. A surcharge will be added to past due support. Unpaid support is a lien by operation of law and the payer's property can be encumbered or seized if an arrearage accrues for more than the periodic support payments payable for two months under the payer's support order. 6. Change of Address, Employment Status, Health Insurance. Both parties shall notify the friend of the court in writing within 21 days of any change in: a) their mailing or residence addresses and telephone numbers; b) the names, addresses, and telephone numbers of their sources of income; c) their health maintenance or insurance companies, insurance coverage, persons insured, or contract numbers; d) their occupational or drivers' licenses; and e) their social security numbers unless exempt by law under MCL 552.603. 7. Fees. The payer of support shall pay statutory and service fees as required by law. 8. Prior Orders. Except as changed in this order, prior provisions remain in effect. Support payable under any prior order is preserved. 9. Other: (attach separate sheets as needed) IT IS SO ORDERED. Plaintiff (if consent/stipulation) Y Date Defendant (if consent/stipulation) Date >'l?ua('GF VKUWA.6MLLANGLuly Date ?l t L - Judge Bar no. L ~? CERTIFICATE OF MAILING I certify that on this date I served a copy of this order on the parties and their attorneys by first-class mail addressed to their last- known addresses as defined in MCR 3.203. Date signature FOC 10b (5/07) UNIFORM SPOUSAL SUPPORT ORDER, PAGE 2 MCL 552.13, MCR 3.211 TA10M & u ULAKIS Wayne Melnick, Esquire Attorney I.D. No.: 53150 36 South Hanover Street CarCkle, Pennsylvania 17013 (717) 249-0900 MARY LYNN BLYSTRA Plaintiff F'. ANDREW RICHARD BLYSTRA Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.. ENFORCEMENT OF FOREIGN JUDGMENT AFFIDAVIT Mary Lynn Blystra, being first dully sworn, deposes and says that: 1. The name of the judgment debtor in this action is Andrew Richard Blystra. 2. The last known post office address of Andrew Richard Blystra is 3005 Market Street, Camp Hill, PA 17011. 3. The Judgment creditor is Mary Lynn Blystra. 4. Mary Lynn Blystra's address is 245 Standish Court, Holland, MI 49423. 5. The foreign judgment for which enforcement is sought is valid, enforceable and unsatisfied. 3 (D O l Date Mary L n ?' Sworn or affirmed to and subscribed before me by Mary Lynn Blystra, this of M CZ.y c. 0- , 2009. r NOTARY PUfi LIC pus.-?,. ?•?? 5?" 55 S 44 =4 r C? jf Cl W ri 3C' ?1 day APR 0 d 2009 -? OM & KU ULAKIS U"gyne Melnick, Esquire Attorug LD. No.: 53150 2 k''ect High Street Carlisle, Peurarylvania 17013 (717) 249-0900 MARY LYNN BLYSTRA Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. ANDREW RICHARD BLYSTRA Defendant TO THE PROTHONOTARY: NO.. ENFORCEMENT OF FOREIGN JUDGMENT AFFIDAVIT Wayne S. Melnick, Esquire, being first dully sworn, deposes and says that: 1. The name of the judgment debtor in this action is Andrew Richard Blystra. 2. The last known post office address of Andrew Richard Blystra is 3005 Market Street, Camp Hill, PA 17011. 3. The judgment creditor is Mary Lynn Blystra. 4. Mary Lynn Blystra's address is 245 Standish Court, Holland, MI 49423. 5. The foreign judgment for which enforcement is sought is valid, enforceable and unsatisfied. Dat Wayne e nick Sworn or affirmed to and subscribed before me by Wayne S. Melnick, thisb day of A10 ?fm iw,. , 2009. Akilov'x NOTARY PUBLIC ? Pennsylvania Commonwealth of NOTARIAL SEAL DEBORAH L. RYAN, Notary Public e chanicsbur(I Soscl., Cow) W of Cumberland My Commission Expires ., Wle 11, 2010 Im Affidavit of Wayne Melnick I, Wayne Melnick, Esquire, an adult individual, do hereby affirm that the following information set forth below is true and correct to the best of my knowledge, information and belief: 1. I have attempted to obtain certified copies in the format as close as required by your office in the filing of such a Praecipe (see my letter to the Clerk of Courts in Allegan County, Michigan, dated October 6, 2009.) 2. I am advised by the Office of Clerk of Courts in Allegan County, Michigan that they do not certify copies of judgments and docket entries in the same manner as we have come to expect from Pennsylvania courts. 3. Instead, the Office of Clerk of Courts in Allegan County, Michigan has provided me with a certification that the copies that accompany the Praecipe are copies of the original papers pertaining to the Michigan judgment. 4. The copies attached to the accompanying Praecipe are the copies provided to me by the Office of Clerk of Courts in Allegan County, Michigan. 5. This Affidavit is provided to set forth my communication with the clerk of Courts of Allegan County, Michigan. ayne M Inick, Esquire COMMONWEALTH OF PENNSYLVANIA: : SS COUNTY OF CUMBERLAND day of 2 2009, before me, the undersigned officer, 00k ?)69iZ On this, the personally appeared Wayne Melnick, Esquire, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Lbcwek- QXI NOTARY PUBLIC ommon ealth of Pennsylvania NOTARIAL SEAL DEBORAH L. RYAN, Notary PLiblic Mechanicsburg ?scrc., Gaunty of Gumberland My ComrThISS1 an Expire.': - .: «* 11, 2010 RLElr-C,-Fl'; i 'E THE 2CC9 NOY 2-0 Fri 1 13 * aq , oo p p ATT-1 p.! 1. r? ICIC cv *t It s3 V* A3K1i5 `V OM c'?' ULILA s 410- Wayne Melnick, Esquire Attorney I.D. No.: 53150 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 MARY LYNN BLYSTRA Plaintiff V. ANDREW RICHARD BLYSTRA Defendant NO.. NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Entry of Foreign Judgment IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEY: WAYNE S. MELNICK, ESQUIRE AT THIS TELEPHONE NUMBER: 717-249-0900 u/04oy /r/ u?do / A;n Q~OM ~' I~uTU~Is Jason P. Kutulakis, Esquire Attorney LD. No.: 80411 Melissa P. Tanguay, Esquire Attorney I.D. No.: 307155 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 MARY LYNN BLYSTRA, Plaintiff v. ANDREW RICHARD BLYSTRA, Defendant TO: PROTHONOTARY ILc:~-Cl~~'tC ~'~l~P`~~F -~ A~~ ~?~ ~~} IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-8221 CIVIL ACTION -LAW Please enter my appearance on behalf of the Plaintiff, Mary Lynn Blystra, in the above- captioned matter. DATE 1 [ ' 3 - ~~ DATE ' / ' Respectfully submitted, M & KUTULAKIS, LLP Jas n P. Kutulakis, Esquire 2 est High Street Carlisle, PA 17013 (717) 249-0900 ID No. 80411 ABOM & KUTULAKIS, LLP Melissa P. Tanguay, Esquire 2 West High Street Carlisle, PA 17013 ''~~,~ (717) 249-0900 ID No. 307155 i l~Ls' ~fi'~ S(F' _ ~~i~ F~'f~~~ --4 ~~~ ~: 5y_~ `'J~~i~EF~L~~°iJ i~Uv~~i ~` 6~E~?~Y~ ~~A~~r~d~:~, _ ~BOM ~' LITLILAKIS Jason P. Kutulakis, Esquire Attorney I.D. No.: 80411 Melissa P. Tanguay, Esquire Attorney I.D. No.: 307155 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 MARY LYNN BLYSTRA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. ANDREW RICHARD BLYSTRA, Defendant NO.: 09-8221 CIVIL TERM TO DAVID BUELL, PROTHONOTARY OF SAID COURT: " 1. .On November 25, 2009, This Honorable Court entered a judgment against Andrew Richard Blystra in the amount of $46,919.00. 2. It has recently come to undersigned counsel's attention that the amount of the judgment entered is erroneous. 3. The judgment includes the amount of $46,919.00, resulting from a July 1, 2008 Order of Court from Allegan County, Michigan regarding equitable distribution in a divorce judgment. 4. The judgment should also include the amount of $19,800.00, resulting from a March 21, 2008 Order of Court from Allegan County, Michigan regarding contempt of a divorce judgment. 5. Both orders were attached to the judgment, but only the $46,919.00 amount was included. 6. The total amount of the judgment should be $66,719.00. WHEREFORE, Mary Lynn Blystra respectfully requests that This Honorable. Court amend the judgment to reflect an amount due of $66,719.00. Respectfully submitted, ABOM&KUTULAKIS, L.L.P. ,~ Date: November 4, 2010-%' ~-~~~L~ Jason P, Kutulakis, Esquire ID No: 80411 ' Melissa P. Tanguay, Esquire ID No.: 307155 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attarn ys for Plaint MARY LYNN BLYSTRA, IN THE COURT OF COMM Plaintiff CUMBERLAND COUNTY, vs. CIVIL ACTION - LAW NO. 09-8221 CIVIL ANDREW RICHARD BLYSTRA, Defendant RE: PLAINTIFF'S ORDER AND NOW, this 5 day of November, 2010, a rule is i P. show cause why the relief requested in the within praecipe ought not to e granted. This rule returnable ten (10) days after service. BY THE COURT, Kevin co'++JlIES /'2ZLLL J. ?" 99"t ? i kcjt ..t?6s o -Lltys4c--?7 PLEAS OF 1NSYLVANIA on the defendant to .b 3 _?w t FILES-BfffCE Of THE PROTHONOTARY 2010 NOV 23 PM 1: 59 CUMBERLAND COUNTY PENNSYLVANIA Mom & K[.iTLILAKIS Jason P. Kutulakis, Esquire Attorney I.D. No.: 80411 Melissa P. Tanguay, Esquire Attorney I.D. No.: 307155 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 MARY LYNN BLYSTRA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. ANDREW RICHARD BLYSTRA, Defendant NO.: 09-8221 CIVIL TERM TO THE HONORABLE KEVIN A. HESS, PRESIDENT JUDGE OF SAID COURT: AND NOW, this 23`d day of November, 2010, comes Jason P. Kutulakis, Esquire and Melissa P. Tanguay, Esquire of ABOM & KUTULAKIS, LLP, and respectfully represents the following: 1. On November 4, 2010, undersigned counsel filed a Praecipe to Amend Judgment in This Honorable Court. 2. On November 5, 2010, The Honorable Kevin Hess, President judge, issued a Rule to Show Cause on the Defendant to show why the Judgment should not be amended, with the Rule returnable ten (10) days from service. 3. On November 10, 2010, Sean M. Shultz, Esquire notified undersigned counsel that he is representing the Defendant in the above-captioned matter. 4. On November 22, 2010, Attorney Shultz notified undersigned counsel that the Defendant does not wish to contest the amendment. 5. More than ten (10) day have passed since service of the Rule and Defendant has not filed a response. WHEREFORE, Petitioner respectfully requests that This Honorable Court enter an Order of Court amending the judgment to reflect an amount due of $66,719.00, as requested in the Praecipe. Respectfully submitted, ABOM & ATM)LAKTS, L.L.P. Date: November 23, 2010 _ Jason P. Kutulakis, Esquire ID No: 80411 J Melissa P. Tanguay, Esquire ID No.: 307155 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorneys for Plaintiff CERTIFICATE OF SERVICE AND NOW, thisZ day of November, 2010, I, Sally Evans of ABOM & KUTULAKIS, LLP, hereby certify that I did serve a true and correct copy of the foregoing Petition upon the following by U.S. Mail, First Class: .Sean M. Shultz, Esquire 4 Irvine Row Carlisle, PA 17013 Andrew Richard Blystra 3005 Market Street Camp Hill, PA 17011 - '116n] & )eaw'-0 Sally Evans Nov 2 4 2010 MARY LYNN BLYSTRA, Plaintiff V. ANDREW RICHARD BLYSTRA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2009-8221 CIVIL TERM AND NOW, this ?4 day of 00 rtvGcc' , 2010, it is hereby ORDERED that the judgment entered by this Court against Andrew Richard Blystra on November 25, 2009 is AMENDED to reflect an amount due of $66,719.00, in accordance with the judgments entered March 21, 2008 and July 1, 2008 in the Circuit Court for County of Allegan, State of Michigan in a divorce action. BY THIS COURT: Kevin A. Hess, President Judge Distribution: Jason P. Kutulakis, Esquire and Melissa P. Tanguay, Esquire, Attorneys for Plaintiff Abom & Kutulakis, LLP, 2 West High Street, Carlisle, PA 17013 Sean M. Shultz, Esquire 4 Irvine Row, Carlisle, PA 17013 drew Richard Blystra, Defendant 3005 Market Street, Camp Hill, PA 17011 c o 0 rnCO _ ? r*? Z M -01 ?n o it .3d/tc? _? z ?Q z- ' y c to 62 -?C i A0 TM & j?LITLILAKIS Jason P. Kutulakis, Esquire Attorney I.D. No.: 80411 Melissa P. Tanguay, Esquire Attorney I.D. No.: 307155 2 West I figh Street Carlisle, Pennsylvania 17013 (717) 249-0900 MARY LYNN BLYSTRA, Plaintiff V. ANDREW RICHARD BLYSTRA, Defendant FILED-OFF`ICE 'Jig DEC -9 PM 3; 07 CUMBERLAND C,?? la ? *< PEN1SvI1_ (p . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-8221 CIVIL TERM TO DAVID D. BUELL, PROTHONOTARY OF SAID COURT: Please enter judgment against the Defendant, Andrew Richard Blystra, and in favor of the Plaintiff, Mary Lynn Blystra, for $66,719.00 in accordance with This Honorable Court's Order of November 29, 2010 amending the amount previously entered. This judgment arises out of judgments entered March 21, 2008 and July 1, 2008 in the Circuit Court for County of Allegan, State of Michigan in a divorce action. to?A?1? .k %\kA. A copy of this Praecipe to Enter Judgment has been mailed to the Defendant at his personal residence at 3005 Market Street, Camp Hill, PA 17011 and to his counsel. Respectfully submitted, ABOM& KUTULAJUS, L.L.P. Date: December 9, 2010 Jason P. Kutulakis, Esquire ID No: 80411 Melissa P. Tanguay, Esquire ?` ID No.: 307155 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorneys for Plaintiff t rIFICATE OF SERVICE C? 1?? AND NOW, this day of December, 2010, I, Sally Evans of Abom & Kutulakis, LLP, hereby certify that I did serve a true and correct copy of the foregoing Praecipe to Enter Judgment upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, first-class mail, postage prepaid addressed to the following: Andrew Richard Blystra 3005 Market Street Camp Hill, PA 17011 Sean M. Shultz, Esquire 4 Irvine Row Carlisle, PA 17013-3019 r Sally Evans MARY LYNN BLYSTRA, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 2009-8221 CIVIL ANDREW RICHARD BLYSTRA, Defendant IN RE: PLAINTIFF'S MOTION TO COMPEL ORDER AND NOW, this 7,1' day of May, 20121 a rule is issued on the defendant to show i cause why the relief requested in the within Motion to Compel ought not to be granted. This rule returnable twenty (20) days after service. BY THE COURT, , (' , d' Kevin AAless, P. J. C.'"] hJ SOn P. S' r-- 5f. Aidreo e. afy 54ne e'o p'e5 ins . /mod s??// IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARY LYNN BLYSTRA, No. 09-8221 Civil Term Plaintiff V. -- co ANDREW RICHARD BLYSTRA, Defendant ' DEFENDANT'S ANSWER TO PLAINTIFF'S MOTION TO COMPEL POST-JUDGMENT DISCOVERY DEMANDS AND NOW, this 15th day of June, 2012, comes Defendant, Andrew Richard Blystra, by and through his attorney, Sean M. Shultz, Esquire, and files the following Answer to Plaintiff's Motion to Compel Post-Judgment Discovery Demands, and in support thereof, avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. It is admitted that Defendant did not return the answers to the Plaintiff's First Set of Post-Judgment Interrogatories within thirty (30) days of service. By way of further answer, Defendant's counsel was in communication with Plaintiff's counsel at the time, Melissa Tanguay, Esquire, and the answers were provided to Attorney Tanguay within the extended time period she offered to Defendant's counsel. 7. Admitted. The Defendant returned answers to the Interrogatories on March 2, 2011. It is denied that the answers to the Interrogatories were untimely returned because Plaintiff's counsel had provided an extension of time until March 2, 2011. It is further denied that the answers were either vague or insufficient, although it is admitted that Defendant failed to recall, and therefore failed to include in his answer to the Interrogatories, that he had a pending lawsuit against him filed by Asset Acceptance, LLC, as a signee of Citi Bank, in the Cumberland County Court of Common Pleas, docket number 2009-1552. That action has since been discontinued by Praecipe dated September 12, 2011. 9. Admitted. 10. Admitted. 11. Admitted. 12. It is admitted that Plaintiff filed the within Motion to Compel. It is denied that the prior answers, other than the item that was highlighted in paragraph 8 above, were not accurate and complete. WHEREFORE, Defendant, Andrew Richard Blystra, requests that this Honorable Court dismiss Plaintiff's Motion to Compel Post-Judgment Discovery Demands. Respectfully Submitted: SAIDIS, SULLIVAN & ROGERS Sean M. Shultz, Esquire Attorney ID No. 90946 26 W. High Street Carlisle, Pennsylvania 17013 (717) 243-6222 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARY LYNN BLYSTRA, No. 09-8221 Civil Term Plaintiff V. ANDREW RICHARD BLYSTRA, Defendant VERIFICATION I verify that the statements made in the foregoing Answer to Plaintiff's Motion to Compel Post-Judgment Discovery Demands are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. Date: 'VuKL /S ZO! Z Andrew Richard Blystra IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARY LYNN BLYSTRA, No. 09-8221 Civil Term Plaintiff V. ANDREW RICHARD BLYSTRA, Defendant CERTIFICATE OF SERVICE AND NOW, this day of June, 2012, I, Sean M. Shultz, Esquire, hereby certify that I have this day served the following person with a copy of the foregoing Defendant's Answer to Plaintiff's Motion to Compel Post-Judgment Discovery Demands by U.S. Regular First Class Mail, addressed as follows: Jason P. Kutulakis, Esquire Abom & Kutulakis 2 West High Street Carlisle, Pennsylvania 17013 Attorney for Plaintiff SAIDIS, SULLIVAN & ROGERS Sean M. Shultz, Es Attorney ID No. 90946 26 W. High Street Carlisle, Pennsylvania 17013 (717) 243-6222 Attorney for Defendant