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Home My WebLink About10-3314SUZETTE D. LEWIS : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF No. ~o - 331 ~ Ca v ~ i Tern vs. . ` ~_ ~, ri MARK D. LEWIS ~v ~~ •;` ° -~ =< T r r, ~' , ~,, ~-; ` DEFENDANT : IN DIVORCE t .= ~: - - -~_' ,_ ~ ,.; ; -, c~ N :.-~ w •< 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 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. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland 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, Pennsylvania 17013 717-249-3166 ~ 34l .50 t^'a ATM C~-~' IOa3 1?~a~a~ c~ ~~~ ~ John A. Davidson, Esquire Attorney I.D. # 200503 The Law Office of John A. Davidson 107 North Front Street Suite 117 Harrisburg PA 17101 Tel: (717) 238-4043 Fax: (717) 238-4198 JAD@JohnADavidsonesq. com SUZETTE D. LEWIS : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF . NO. VS. MARK D. LEWIS, DEFENDANT : IN DIVORCE COMPLAINT UNDER SECTION 3301 (a) (6) 3301(c) or SECTION 3301(d) OF THE DIVORCE CODE And Now Comes the Plaintiff, Suzette D. Lewis, an adult individual, by her attorneys, The Law Office of John A. Davidson 1. Plaintiff is Suzette D. Lewis, who currently resides at 722 Edson Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2 Defendant is Mark D. Lewis, who currently resides at 5215 Stuart Drive., Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on Apri128, 1989, at Denver, Colorado. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. This marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Defendant has offered such indignities to Plaintiff, who is the innocent and injured spouse, so as to render Plaintiff's condition intolerable and life burdensome. 10. The parties to this action separated on October 15, 2009 11. Plaintiff requests the court to enter a decree of divorce under Section 3301(a) (6) 3301(c) or Section 3301 (d) of The Divorce Code. Wherefore the Plaintiff requests the Court enter a decree of divorce under Section 3301(a) (6) or Section 3301(c) or Section 3301 (d) of The Divorce Code. Page 2 of 4 COUNTI R_~UEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(a) OF THE DIVORCE CODE 12. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 13. .Plaintiff and Defendant have acquired marital property as defined by the Divorce Code, which is subject to equitable distribution pursuant to Section 3502(a) of the Divorce Code. 14. Plaintiff and Defendant have been unable to agree as to the equitable division of said property, as of the date of the filing of this Complaint. 15. Plaintiff requests that the Court equitably divide, distribute or assign the marital property between the parties. WHEREFORE, Plaintiff respectfully requests that the Court enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. Respectfully Submitted The Law Office of ohn A. Davidson Dated: May 11, 2010 By Jo A. Davidson ID # 200503 107 North Front Street Suite 117 Harrisburg, PA 17101 Attorney for Suzette D. Lewis Plaintiff Page 3 of 4 ~, VERIFICATION I, Suzette D. Lewis, hereby acknowledge that I am the Petitioner in the foregoing action; that I have read the foregoing document; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dat „ ~~ Suzette .Lewis Page 4 of 4 SUZETTE D. LEWIS, Plaintiff MARK D. LEWIS, To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-3314 CIVIL TERM v. Defendant ACTION IN DNORCE C ° ` - n .-~ -~ ~ s-- ~ ".~.~ ~:. ~ n .:, l -iJ +...~ ...:.~v iV =-i ~ s PRAECIPE TO ENTER APPEARANCE Kindly enter my appearance on behalf of the Defendant, Mark D. Lewis. COYNE & COYNE, P.C. Dated: lP a3 ~~ By: _ 'me L. High, Esqui Pa. S. Ct. No. 3901 Market Street Camp Hill, PA 17011-4227 (717)737-0464 Attorney for Defendant COYNE & COYNE, P.C. Jaime L. High, Esquire Pa. Supreme Ct. No. 91506 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 SUZETTE D. LEWIS, Plaintiff V. MARK D. LEWIS, Defendant FIL Tit! 2011 U B?.RL f VA &I I'A Attorney for Defendant IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 10-3314 CIVIL TERM ACTION IN DIVORCE ANSWER TO COMPLAINT TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW COMES, Defendant, MARK D. LEWIS, by and through his counsel, Jaime L. High, Esquire, of Coyne & Coyne, P.C., and files this Answer and Counterclaim: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. Defendant retired from the U.S. Army in June, 2009. 1 7. Denied. The averments contained in Paragraph 8 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Defendant is without sufficient knowledge or information to form belief as to the truth of the remaining averments of Paragraph 7 and the same are therefore denied and strict proof is demanded at the time of trial. 8. Denied. After reasonable investigation, Defendant is without sufficient knowledge or information to form belief as to truth of the averments of Paragraph 8 and Defendant has no knowledge of what, if anything, the Plaintiff was advised and same is therefore denied and strict proof is demanded at the time of trial. 9. Denied. It is specifically denied that Defendant has offered such indignities to Plaintiff so as to make Plaintiff's condition intolerable and life burdensome. Strict proof is demanded at time of trial. 10. Admitted. 11. Neither admitted nor denied, as this is a conclusion of law to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied and strict proof is demanded at the time of trial. WHEREFORE, Defendant respectfully requests this Honorable Court dismiss the request for entry of a decree of Divorce under Section 3301(a)(6)(c)(d) of the Divorce Code. 2 COUNTI REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(a) OF THE DIVORCE CODE 12. Paragraphs 1 through 11 are incorporated herein by reference. 13. Admitted. 14. Admitted. 15. Admitted. WHEREFORE, Defendant requests this Honorable Court to equitably divide all marital property and debt pursuant to the Divorce code. Dated: ?? Respectfully submitted: COYNE & COYNE, P.C. By: ,Imifiie L. High,/E ire Pa. S. Ct. No. 506 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney for Defendant VERIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S.A. § 4904. .- Dated: 1613 ;Z. C) (I MARK D. LEWI CERTIFICATE OF SERVICE I, Jaime L. High, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Answer was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid: John A. Davidson, Esquire 107 North Front Street, Suite 117 Harrisburg, PA 17101 Dated: °? ?P << Jai . High, Esquire a. S. Ct. No. 91506 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorney for Defendant SUZETTE D. LEWIS : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANI A2 J' PLAINTIFF _ r,; NO. 2010 03314 Civil Term =::o rn vs. "7 ?c N ar r MARK D. LEWIS, DEFENDANT : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER [ ] Plaintiff [ ] Defendant, moves the court to appoint a master for the following claims: [X] Divorce [X] Distribution of Property [ ] Annulment [ ] Alimony [ ] Alimony Pendente Lite [ ] Support (] Counsel Fees [ ] Costs and Expenses and in support of this motion states 1. Discovery [] is [X] is not complete as to the claim(s) for which the appointment of a master is requested. 2. The non-moving party [ X ] has [ ] has not appeared in the action [ ] Personally [ X ] by Counsel, Jaime L. High, Esquire 3. The statutory grounds for divorce [ X ] is [ ] are Part 3301(d) of the Divorce Code 4. The action is contested with respect to the following claims: The dissolution of the marriage and the division of property acquired during the marriage 5. The Action [ ] involves [X] does not involve complex issues of law or fact 6. The Hearing is expected to take four (hours) (days) 7. Additional information, if any, relevant to the motion: Attached to this motion are Exhibit A, Plaintiff's income statement and Exhibit B Plaintiff's expense statement Date: 2/21/2012 Jbhn A Davidson Attorney for Plaintiff EXHIBIT A SUZETTE D. LEWIS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF NO. 2010 03314 Civil Term VS. MARK D. LEWIS, DEFENDANT :IN DIVORCE INCOME STATEMENT OF (Suzette D. Lewis) (603112176) I verify that the statements made in this Income Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. te&)C) ??- D I?- ?5 (Plaintiff) INCOME: Employer: Stanley Black & Decker Address: 2201 Industrial Highway York, PA. 17402 Type of work: Service Representative Pay Period: Weekly Payroll Number: 170490 Gross pay per pay period: 632.80 Itemized Payroll Deductions Federal Withholding 17.13 FICA 34.99 Local Wage Tax 1.00 State Income Tax 16.21 Mandatory Retirement Union Dues Health Insurance (Dental) 13.38 Other (Unemployment, 5.03 Disability, And Life Insurance) Net Pay per Period: 536.06 INSURANCE Hospital Blue Cross Other Medical Blue Shield Other Coverage Company Policy No. H W C Health/Accident Disability Income Dental Cigna 2498633 Other Other Income Interest Dividends Pension Distribution Annuity Social Security Rents Royalties Unemployment Comp Workers Comp Employer Fringe Benefits Other (Spousal Support) Total TOTAL INCOME PROPERTY OWNED Checking Accounts Savings Accounts Credit Union Stocks/Bonds Real Estate Other Description Bank of America Bank of America Pentagon Federal Total Week Month Year 100.00 33.00 5196.00 636.06 2321.14 27853.68 Value 1200 300 2584 4084 Ownership H W J X X X EXHIBIT B f EXPENSE STATEMENT OF (Suzette D. Lewis) (603112176) I verify that the statements made in this Expense Statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date i 2 Mortgage (including real estate taxes and homeowner's insurance) or Rent Health Insurance Premiums Unreimbursed Medical Expenses Doctor Dentist Orthodontist Hospital Medicine Special Needs (glasses, braces, orthopedic devices therapy) Child Care (Plaintiff) Weekly Monthly Yearly $210.16 910.00 10920.00 13.38 57.93 695.16 Private School Parochial school Loans/Debts Support of Other Dependents Other Child Support Alimony Payments Other (Spousal Support) Total 269.74 1168.00 14016.00 93.28 2135.93 25901.16 CERTIFICATE OF SERVICE And Now, on this 21h day of February 2012 I, John A. Davidson, attorney for the Petitioner, Pierre B. Eugene, hereby certify that I have served true and correct copies of the within documents, on Jaime L. High, Esquire, attorney for the Respondent by depositing same to in the United States Mail, postage prepaid addressed as follows: Jaime L. High, Esq. Coyne and Coyne 3901 Market Street Camp Hill, PA 17011: The Layv Office of Join A. Davidson By John A. Davidson ID # 200503 117 North Front Street Suite 117 Harrisburg, PA 17101 Attorney for Plaintiff/Petitioner 21 ORDER And Now Esquire Is appointed master with respect to the following claims: By The Court J. MOVING PARTY Suzette D. Lewis ',,/John A. Davidson, ESQ. 117 North Fomt Street Suite 107 Harrisburg, PA. 17101 (717) 2354043 JAD@JohnADavidsonEsq.com: CCpie5, dye I ??? ?/ y// NON-MOVING PARTY Mark D. Lewis ? Jaime L. High Esquire Coyne and Coyne 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Jaime@CoyneandCoyne.com r") C r,, to -D rr, (7J C.7 : C i `D COYNE & COYNE, P.C. ?, ?;+}l,yt t ,,t , Jaime L. High, Esq. 11: 50, Pa. Supreme Ct. No. 91506 Lit 3901 Market Street filiM. B .RLAiC C0U,i Camp Hill, PA 17011-4227 ?ENNS?1 ?A1 (717) 737-0464 PETITIONER SUZETTE D. LEWIS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-3314 CIVIL TERM MARK D. LEWIS, ACTION IN DIVORCE Defendant PETITION TO WITHDRAW AS COUNSEL FOR DEFENDANT TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW comes, Jaime L. High, Esquire, counsel for Defendant and avers the following in support of her request for permission to withdraw from representation of Defendant in this matter. 1. On or about June 19, 2010, the Defendant, Mark D. Lewis, engaged the professional services of undersigned legal counsel in representing him in the Divorce Action. 2. There are irreconcilable differences between the Petitioner and the Defendant. 3. Defendant will not be prejudiced if Petitioner is allowed to withdraw from the case. 4. The Petitioner requests Court permission to withdraw from representation of Defendant in this matter. 5. Judge Albert H. Masland has prior involvement with this case regarding a support action. WHEREFORE, the Petitioner, Jaime L. High, Esquire, requests this Honorable Court to grant her withdrawal as legal counsel of record for the Defendant. Dated Respectfully submitted: COYNE & COYNE, P.C. f ?- f By: , Jaime L. High, Esquire' ' 3901 Market Str6et Camp Hill, PA 17011 (717) 737-0464 Pa. Supreme Ct. No. 91506 Petitioner CERTIFICATE OF SERVICE I, Jaime L. High, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Petition to Withdraw as Counsel was served this date upon the below-referenced individual at the below listed address by way of first class mail, postage pre-paid: Mr. Mark D. Lewis 5215 Stuart Drive Mechanicsburg, PA 17055 1 Dated: '?airne L. High, Esquire 3901 Market Street L Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 91506 Petitioner SUZETTE D. LEWIS, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-3314 CIVIL TERM MARK D. LEWIS, ACTION IN DIVORCE Defendant AND NOW this day of March, 2012, upon consideration of the Petition of Jaime L. High, Esqu* e, to Withdraw as Counsel for Defendant, a Rule is issued upon the n(4,N6q kktt Defendant to show cause why the Petition should not be granted. This Rule is Returnable By the Court: Cf. /Jaime L. High, Esq. Petitioner v1 Mark D. Lewis Respondent RULE TO SHOW CAUSE is days after Service t. C-) C 1'? vZ rr7 Co ;:::; ? ? c C J COYNE & COYNE, P.C. `'? ?C TNC= urn 1, tt; i Jaime L. High, Esq. 2012 A PR 31 I 1 4 0 Pa. Supreme Ct. No. 91506 3901 Market Street NBERLAiZ CUUNP41 PEf?;°?SYLV,4hl,, Camp Hill, PA 17011-4227 (717) 737-0464 PETITIONER SUZETTE D. LEWIS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 10-3314 CIVIL TERM MARK D. LEWIS, ACTION IN DIVORCE Defendant MOTION TO MAKE RULE ABSOLUTE TO THE HONORABLE JUDGE ALBERT H. MASLAND: And now comes the Petitioner, Jaime L. High, Coyne & Coyne, P.C. avers the following in support of this Motion to Make Rule Absolute: 1. On March 2, 2012, Petitioner filed a Petition to Withdraw as Counsel. 2. On March 5, 2012, this Honorable Court issued a Rule upon the Respondent, Mark D. Lewis and John A. Davidson, Esq., Attorney for the Plaintiff, to show cause why the undersigned petitioning attorney should not be permitted to withdraw and directed that the Rule is returnable fifteen (15) days after service. 3. On March 6, 2012, the Rule was served by first-class mail by the Cumberland County Prothonotary's Office. 4. More than fifteen days has expired since the issuance of the Rule upon the Respondents and which no response or objection has been forthcoming. WHEREFORE, the Petitioner, Jaime L. High, Esquire, respectfully prays that this Honorable Court to allow Petitioner to withdraw as counsel of record for Mark D. Lewis. COYNE & COYNE, P.C. Dated. y . ime L. H' squire 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 91506 2 CERTIFICATE OF SERVICE I, Jaime L. High, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Motion to Make Rule Absolute was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid: Mark D. Lewis 5215 Stuart Drive Mechanicsburg, PA 17055 John A. Davidson, Esq. 117 North Front Street, Suite 107 Harrisburg, PA 17101 ? f)4 Dated: ("'- Jaime L. High, squire 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 91506 Petitioner 3 cvl? - -, I SUZETTE D. LEWIS, Plaintiff V. MARK D. LEWIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-3314 CIVIL TERM ACTION IN DIVORCE ORDER AND NOW this day of s^i , 2012, it appearing that Mark D. Lewis and John A. Davidson, Esq., Respondents, were served on March 6, 2012 a Rule to Show Cause why Petitioner, Jaime L. High, Esquire, should not be permitted to withdraw as counsel for Mark D. Lewis, and upon receipt of service, the Respondents did not answer said Rule within fifteen (15) days of service of same, Petitioner, Jaime L. High, Esquire of the Law Firm of Coyne & Coyne, P.C. is hereby granted permission to withdraw as counsel of record for Mark D. Lewis. BY THE COURT: C£ V Jaime L. High, Esq. Petitioner i/ Mark D. Lewis, Respondent John D. Davidson, Esquire, Respondent CSC F? ?5 ?viGt ???? ?( ?.5'?/ ? Albert H Masland J -? . , . r 1 H..' u F,,•f 1? ?« S la ?... "ice i'ROTHONGTA'41 COYNE & COYNE, P.C. 2012 APR 10 AM 11: 29 Jaime L. High, Esq. Pa. Supreme Ct. No. 91506 CUMBERLAND COUNT' 3901 Market Street PENNSYLVANIA Camp Hill, PA 17011-4227 (717) 737-0464 PETITIONER SUZETTE D. LEWIS, Plaintiff V. MARK D. LEWIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-3314 CIVIL TERM : ACTION IN DIVORCE PREACIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Pursuant to the Order of Court, kindly withdraw my appearance in this matter for Defendant, Mark D. Lewis. COYNE & COYNE, P.C. Dated: I r /f? f' Be aime L. High, Esquire 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 91506 CERTIFICATE OF SERVICE I, Jaime L. High, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Petitioner's Preacipe to Withdraw was served this date upon the below-referenced individuals at the below listed address by way of first class mail, postage pre-paid: Mark D. Lewis 5215 Stuart Drive Mechanicsburg, PA 17055 John A. Davidson, Esq. 117 North Front Street, Suite 107 Harrisburg, PA 17101 Dated: me L. High, squire 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 91506 Petitioner 2