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Home My WebLink About04-3098IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA A. STRAHOSKY, Plaintiff CIVIL ACTION - LAW V. NO. 2004- 9092 MICHAEL T. STRAHOSKY, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment maybe entered against you bythe Court. A judgment may also be entered against you for any other claim or reliefrequestedinthese papers bythePlaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list ofmarriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be home by you and your spouse. Ifyou desire to pursue counseling, you must make your request for counseling within twenty (20) days ofthe date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPERTO YOURLAWYERAT ONCE. IFYOU 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 Street Carlisle, Pennsylvania 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BARBARA A. STRAHOSKY, Plaintiff CIVIL ACTION - LAW V. NO. 2004- .3098 MICHAEL T. STRAHOSKY, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 2"d day ofJuly, 2004, comes Plaintiff, Barbara A. Strahosky, by and through her attorneys, Hanft & Knight, P.C., and files the following Complaint in Divorce, and in support thereof avers as follows: COUNTI DIVORCE 1. The Plaintiff is Barbara A. Strahosky, who currently resides at 529 Bedford Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Michael T. Strahosky, who currently resides at 215 CalvalryRoad, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth ofPennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on July 11, 1998, in Cumberland County, Pennsylvania. 5. The marriage is irretrievably broken. The foregoing facts are averred and brought The marriage is irretrievably broken. The foregoing facts are averred and brought under Sections 3301(c) and 3301(d) of the Divorce Code of 1980, as amended. 6. Alternatively, Plaintiff avers that the Defendant has offered such indignities to her, the injured and innocent spouse, as to renderher condition intolerable and her life burdensome. The foregoing facts are averred and brought under Section 3301(a)(6) of the Divorce Code of 1980, as amended. 7. The Plaintiffhas been advised ofthe availability ofcounseling, and that the Plaintiffmay have the right to request that the Court require the Parties to participate in counseling, and Plaintiffwaives same. WHEREFORE, Plaintiffrequests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. COUNT II REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTIONS 3104 AND 3105(a) OF THE DIVORCE CODE 8. Paragraphs 1 through 7 are incorporated herein by reference. 9. Plaintiffand Defendant have acquired property, bothreal andpersonal during theirmarriage from the date of said marriage until the date of their separation. 10. Plaintiffand Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. 11. Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property. WHEREFORE, Plaintiffrespectfullyrequests the Court to equitablydistribute the marital property of the parties and equitably apportion their debts pursuant to the Divorce Code of 1980, as amended. COUNT III ALIMONY 12. Paragraphs 1 through 12 are incorporated herein by reference. 13. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment 14. Plaintiffrequires reasonable support to adequatelymaintain herself in accordance with the standard of living during the marriage. WHEREFORE, Plaintiffrequests YourHonorable Court to enter an award of alimony in her favor. Respectfully submitted, HANFT & KNIGHT, P.C. -<41e" i - r- Michael J. Hanft, Esquire Attorney ID No. 57976 Sean M. Shultz, Esquire Attorney ID No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff F:\Usc, Folda\Fimi Dou\G<ndoce\Gmdocs:W3U 143-1 div.com.wpd VERIFICATION I VERIFY that the statements set forth in the attached document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made C subject to the penalties of 18 Pa. Section 4904 relating to unswom falsification to authorities. F \Uur FotdeFmn DxeFormelmgatlon\Vcrifiution gcncnc 6 v; RJ s. ? a v? R ? r4 U BARBARA A. STRAHOSKY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004 - 3098 v MICHAEL T. STRAHOSKY, CIVIL ACTION -LAW Defendant : IN DIVORCE PRARCIPF D FNTFR APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Broujos and Gilroy, P.C., and Hubert X. Gilroy, Esquire, on behalf of the Defendant in the above matter. H bert X. ilroy, Esquire Attom for Defendant Bro os & Gilroy, PC 4 North Hanover Street Carlisle, PA 17013 717-243-4574 r? ` ? s o ? r -- '? ; ? . ' ?? R !} fir' : --rte w {??? _.?- . ?`}(f1 r: C?J C Barbara Strahosky, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW Michael Strahosky, Defendant : NO. 2004- 3098 CIVIL TERM WITHDRAWAL AND ENTRY OF APPEARANCE TO THE PROTHONOTARY OF SAID COURT: PLEASE withdraw my appearance as attorney of record for the Petitioner, Barbara Strahosky, at the above captioned docket. Dated: 3 V4166 Suite B Carlisle, PA 17013-8806 PLEASE enter my appearance as attorney of record on behalf of the Petitioner, Barbara Strahosky, at the above captioned docket. Re*pectfully sZ77 uIUti'a " ?tZ auren Nav Ikowsky Certified Legal Intern ROB S THOMA M. PLACE LUCYJOHNSTON-WALSH ANNE MACDONALD-FOX WILLIAM G. MARTIN FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 - = - ? r, ?; ?? ?_? ?.; -- BARBARA STRAHOSKY, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW MICHAEL STRAHOSKY, : DIVORCE Defendant No. 04-3098 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Divorce Complaint at the above-captioned docket. eith Hickman Certified Legal Intern Y G Anne a onald-Fox ` Supervising Attorney Date: July 12, 2006 BARBARA STRAHOSKY, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW MICHAEL STRAHOSKY, : DIVORCE Defendant : No. 04-3098 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Divorce Complaint at the above-captioned docket. Laren Navalkowsky Certified Legal Intern Megan iesmeyer, Esq. Supervising Attorney Date: September 27, 2006 N U 4 1 j on ? a BARBARA STRAHOSKY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW IN DIVORCE MICHAEL STRAHOSKY, Defendant NO. 04 -3098 CIVIL TERM AFFIDAVIT OF SERVICE I, Lauren Navalkowsky, hereby certify that I personally served a true and correct copy of the reinstated Divorce Complaint, on Michael Strahosky, at his place of business: 255 S. Spring Garden St, Carlisle, PA 17013 at 1:30 p.m. on October 11, 2006. 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: October 11, 2006 Lauren Navalkow y Certified Legal Inte r L cy J oLnston-Walsh Esq. Supervising Attorney C? ''? v _- .r? . i r--? ---I ?? ,..-? I '"C:? __ C.t.? -? r`-' BARBARA STRAHOSKY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - IN DIVORCE NO. 04-3098 MICHAEL STRAHOSKY, Defendant INVENTORY OF BARBARA STRAHOSKY Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Barbara Strahosky, Plaintiff ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( ) 1. Real Property O 2. Motor Vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( ) 5. Checking accounts, cash ( ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, inventories, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits - severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans () 18. Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits () 24. Debts due, including loans, mortgages held (X) 25. Household furnishings and personalty (which have already been divided by the parties) (X) 26. Other (miscellaneous property which has already been divided by the parties) MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number 19. 26. 25. 25. 25. Description Of Property 401(k) account *Profits acquired in sale of marital property Michael Strahosky Barbara Strahosky *Household Furniture Michael Strahosky Barbara Strahosky *Household Electronics *Sporting Equipment Names of All Owners Michael Strahosky Michael Strahosky Barbara Strahosky Michael Strahosky Barbara Strahosky *Denotes marital property that has been divided among the parties and is no longer an issue in this case. NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description Of Property Reason for Exclusion PROPERTY TRANSFERRED Item Description Date of Consid- Number of Property Transfer eration LIARILITTFS Person to whom Transferred 3 Item Description Names of Names of Number of Property All Creditors All Debtors Plaintiff reserves the right to correct and/or supplement this Inventory to the extent that she acquires additional information regarding assets and/or liabilities. 4 r--? C` ..? 1; -,. ? , r?t rig ?=?= ?- ? .. -t^ `: s ?. -i .._. C'SJ Ms. Barbara Strahosky, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Mr. Michael Strahosky, Defendant NO. 04 - 3098 CIVIL TERM PRAECIPE TO WITHDRAW ALIMONY COUNT To the Prothonotary: Please withdraw the Count for Alimony in the above-captioned matter filed in the Cumberland County Courthouse on July 2, 2004. Date: Wa Certified Legal Intern &J-4Z Lucy J ston-Walsh Anne MacDonald-Fox Thomas Place Robert Rains Megan Riesmeyer Supervising Attorneys The Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 (717)243-2968 ?? C?'i .._. t J? . - ?? 3 1 ''- . _. . _ ?t'? ? 4s'.? . } ; ? . to ij Ms. Barbara Strahosky, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Mr. Michael Strahosky, Defendant NO. 04 - 3098 CIVIL TERM CERTIFICATE OF SERVICE I, Warren Eth, Certified Legal Intern, Family Law Clinic, hereby certify that on February 9, 2007, I served a true and correct copy of the Praecipe Count on Withdraw Alimony to Hubert X. Gilroy, Esq. counsel of record for Defendant, Michael Strahosky by First Class, US Mail, postage prepaid, addressed to 10 East High Street, Carlisle, PA 17013. 7, 9 0? Date Warren Certified Legal Intern Megan iesmeyer Lucy Johnston-Walsh Anne MacDonald-Fox Thomas M. Place Robert E. Rains Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 !?' n,7 ,-,_.z l„?+ ,? -7-- -,...i tl { , '? T ? ?: ?--. _ e ?Sb ..3 ., ?,? f i Ms. Barbara Strahosky, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Mr. Michael Strahosky, Defendant NO. 04 - 3098 CIVIL TERM CERTIFICATE OF SERVICE I, Warren Eth, Certified Legal Intern, Family Law Clinic, hereby certify that on February 9, 2007, I served a true and correct copy of the Inventory of Barbara Strahosky on Hubert X. Gilroy, Esq. counsel of record for Defendant, Michael Strahosky by First Class, US Mail, postage prepaid, addressed to 10 East High Street, Carlisle, PA 17013. q o? Date Megan Itiesmeyer Lucy Johnston-Walsh Anne MacDonald-Fox Thomas M. Place Robert E. Rains Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 CZ i _'4 Barbara Strahosky, Plaintiff V. Michael Strahosky, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE : NO. 04 - 3098 CIVIL TERM PLAINTIFF'S REQUEST FOR THE PRODUCTION OF DOCUMENTS Pursuant to Pennsylvania Rules of Civil Procedure 4009.11 and 4009.12, the Plaintiff propounds the following document request to the Defendant, which must be proffered fully, within thirty (30) days of service hereof: 1. All documents related to Defendant's pension with Giant Supermarkets, a subsidiary of Ahold USA, including but not limited to the last 12 months of pension statements, receipts or stubs as well as any and all documents regarding loans or advances taken out against the pension and all plan specific documents including tax and disbursement information. Include the name and address of the Plan Administrator and any other relevant contact information. You or your attorneys are requested to bring the documents listed herein for inspection and copying at the Family Law Clinic, 45 North Pitt Street, Carlisle, PA 17013. The Request for the Production of Documents shall be deemed continuing, requiring new responses as you receive new information, as required pursuant to Pa.R.C.P. 4007.4. DATE: S - en 4ertifie*;dLegal Intern ROB RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 717-243-3639 ;T1 Barbara Strahosky, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Michael Strahosky, Defendant NO. 04 - 3098 CIVIL TERM CERTIFICATE OF SERVICE I, Warren Eth, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of Plaintiff's Request for the Production of Documents, to Defendant's attorney of record Hubert X. Gilroy, Esquire 10 East High Street, Carlisle, PA 17013 by depositing a copy of the same in the United States mail. DATE: Az:eke ROB ' T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Phone 717-243-2968 Fax 717-243-3639 r--l Q c-S -{ , Barbara Strahosky, Plaintiff V. Michael Strahosky, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 04-3098 CIVIL TERM PLAINTIFF'S MOTION TO COMPEL PRODUCTION OF PENSION RECORDS BY DEFENDANT COMES NOW the Plaintiff, Barbara Strahosky, by her attorneys, the Family Law Clinic, and moves this Honorable Court to compel Defendant to produce his pension records, and states the following in support thereof: 1) On July 2, 2004 Barbara Strahosky filed the above captioned divorce action with counts for equitable distribution and alimony against Michael Strahosky, which was reinstated September 27, 2006. 2) On December 19, 2006 Plaintiff filed an inventory with the Court. 3) On February 9, 2007 Plaintiff withdrew the alimony count. 4) On February 9, 2007 attorney for Defendant, Hubert X. Gilroy, Esquire, was served with copies of Mrs. Strahosky's inventory as well as the Pracecipe to Withdraw the alimony count. 5) On April 3, 2007 Certified Legal Intern, Warren Eth, requested Defendant's pension information from Mr. Gilroy's office. 6) On April 12, 2007 a letter was sent to Mr. Gilroy (Plaintiff's Exhibit A) reciting the phone conversation of April 3, 2007 and renewing the request for the pension documents. 7) To date this office has received none of the requested information. 8) On June 5, 2007 Plaintiff filed with the Court and served on opposing counsel a formal request pursuant to Pa.R.C.P. 4009.11 and 4009.12 specifically requesting Defendant's pension information with Ahold USA, the parent company of Giant Supermarket. On this date a second letter was sent to opposing counsel requesting the pension information (Plaintiffs Exhibit B) and enclosing the request for production of documents (Plaintiffs Exhibit Q. 9) On June 12, 2007, this office received a letter from opposing counsel indicating the he had forwarded all the past requests, including the most recent, to Defendant and had received no response (Plaintiffs Exhibit D). On July 9, 2007, this office contacted Mr. Gilroy's office and spoke to his paralegal who indicated they had not been contacted by Mr. Strahosky. 10) Thirty days have elapsed since service of the Request for the Production of Documents and Defendant has not complied. 11) Plaintiff now requests that this Honorable Court compel Defendant to produce the requested information. 12) Pursuant to Local Rule 202.8(d), concurrence of opposing counsel was sought, but could not be obtained. 13) There has been no Judge assigned to this case. WHEREFORE, Plaintiff requests that this Honorable Court compel Mr. Michael Strahosky to immediately provide to his attorney or the Family Law Clinic the following information: [A]11 documents related to Defendant's pension with Giant Supermarkets, a subsidiary of Ahold USA, including but not limited to the last 12 months of pension statements, receipts or stubs as well as any and all documents regarding loans or advances taken out against the pension and all plan specific documents including tax and disbursement information such information shall include the name and address of the Plan Administrator and any other relevant contact information. Respectfully Submitted, II / DATE: 0? /-JL?iOiied Legal Intern ROBE AT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN REISMEYER Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Phone 717-243-2968 Fax 717-243-3639 VERIFICATION I, Warren Eth, Certified Legal Intern, hereby verify that the information contained in this application, including all statements, representations, and other entries, is true and correct to the best of my knowledge, information and belief. This verification is made subject to the penalties of 18 PA. C. S. §4904, relating to unsworn falsification to authorities. DATE: qlllOq Family Law Clinic The Dickinson Family Law Clinic The Date F. Shughart FXT- ® School of Law Community Law Center A service to the community by students 45 North Pitt Street from Penn State University's Dickinson Carlisle, PA 17013 School of Law Office: 717-243-2968 or 717-243-8034 F Fax: 717-243-3639 April 12, 2007 Mr. Hubert X. Gilroy ?, PL14W" S 10 East High Street EXIT Carlisle, PA 17013 Re: Strahosky v. Strahosky, 04-3098 1 Dear Mr. Gilroy, This letter is to confirm the conversation I had with your paralegal Shelly on April 10, 2007 in regards to the Strahosky matter. The conversation regarded Mr. Strahosky's pension information. Shelly has informed me that she has had a conversation with Mr. Strahosky and that Mr. Strahosky will send the information to your office. After your office receives the information, Shelly has informed me she will forward copies to me, at the Family Law Clinic. Thank you for your office's assistance in this matter and I look forward to receiving the pension information and contacting you to conclude this matter as soon as possible. If you have any questions or concerns regarding this matter, please feel free to contact me. Sincerely,, Certified Legal Intern CC: File An Equal Opportunity University The Dickinson Family Law Clinic The Dale F. Shugart School of Law Community Law Center ARV A service to the community by students ?,??r o S from The Dickinson School of Law of t (? s7 3U ? /? The Pennsylvania State University \ ce. 4 U Hubert X. Gilroy, Esq. Fax. 71?-243-3 9 10 East High Street Carlisle, PA 17013 FILE June 5, 2007 RE: Strahosky v. Strahosky, 04-3098 Dear Mr. Gilroy: Enclosed please find Plaintiffs. Request for the Production of Documents in the above divorce action. Our client, Mrs. Strahosky has expressed a desire to conclude this action as soon as possible. On February 9, 2007 1 gave notice to your office that we had filed Plaintiffs inventory. To date we have yet to receive your client's inventory. Hopefully we will receive Mr. Strahosky's inventory shortly, as well as the pension information, so we can conclude this matter. If you have any questions or concerns please feel free to contact me at the Clinic. Enclosures CC: Mrs. Strahosky File Tt- - `- -I-;-+- crhnni of Law of The Pennsylvania State University An Equal Opportunity University Plaintiff V. Michael Strahosky, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANU CIVIL ACTION-LAW DIVORCE : NO. 04 - 3098 PLAINTIFF'S REQUEST FOR THE PRODUCTION OF CIVIL TERM 0 0 S CP Pursuant to Pennsylvania Rules of Civil Procedure 4009.11 and 4009.12, the-taint propounds the following document request to the Defendant, which must be pr4k- ed fully, within thirty (30) days of service hereof: ,- ` a r0k r? y r .s? 1. All documents related to Defendant's pension with Giant Supermarkets, a subsidiary of Ahold USA, including but not limited to the last 12 months of pension statements, receipts or stubs as well as any and all documents regarding loans or advances taken out against the pension and all plan specific documents including tax and disbursement information. Include the name and address of the Plan Administrator and any other relevant contact information. You or your attorneys are requested to bring the documents listed herein for inspection and copying at the Family Law Clinic, 45 North Pitt Street, Carlisle, PA 17013. The Request for the Production of Documents shall be deemed continuing, requiring new responses as you receive new information, as required pursuant to Pa.R.C.P. 4007.4. DATE: 0 0 S r en ertified Legal Intern ROB . RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLMC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 717-243-3639 ? RT` N C,AY.I. C. Rlc!_Ei . • W 1014N S. FCAL£R III LAW F F ? S DANIEL K. DK' E .XMU.I- C-'iRLSIOPRM E. RiCL _ 1- V Tfi *v` sJ. ?'ILtl„bi''+? _TEhTITTTR L. SPEARS No V. Caro III Mlcx.?sl,} Cola NS 10 &%sr HIGH STAIN' Hulssrzr X. Gi1.ucn' Sr.-f- K T. D4txs.BEY C'musuE PENNSYI`ANiA 17013 ' Ga1Rcr. B. FA I.i.RR JR., TP-LE'PHo NE (71,7) 243-3341. •BoARD CIPTIMC CT%!LThc. SPECLILusT FAC9ZGL , (717) 243-1850 ITT[:RN t' vmwma lsookw am June 12, 2007 V LA FAf,,SINIILE mi an iA3-3639 Warren.Eth; Certified. Legal Intern PLAINTIFF'S Dickinson School of Law Family Law Clinic EXHIBIT 45 North Pitt Street Carlisle, PA 17013 RE: Strahosky v. Strahosky / Docket No. 04-3098 Our File No. 12414 Dear Mr. Eth: I have forwarded your June 5, 2007 letter onto Mr. Strahosky and I will contact you whim I hear back from you. I had previously forwarded your correspondence onto Mr. Strahosky and I have not heard from him. Very truly yours, MAR. 4 LAW OFFICES : X.' Crilroy HXGfsrb cc: Mr. Michael Stiahosky F:1F1L8SIderwnP.Ctursn4(?AM;1241-0.wcl I N F O R M A T I O No A D V I • c E A D V O C A C Y li,777 ?.i?_ J N r;?? :, 's'1 t". ::?s C..^ ??°J ? - ?_ -l ? ;.! Ms. Barbara Strahosky, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Mr. Michael Strahosky, Defendant NO. 04-3098 CIVIL TERM CERTIFICATE OF SERVICE I, Warren Eth, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of Plaintiffs Motion to Compel Production of Pension Records by Defendant on Mr. Hubert X. Gilroy, Esq. Defendant's attorney, at 150 East High Street, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, postage prepaid, on Wednesday, July 11, 2007. DATE: ol I l U 7 ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN REISMEYER Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 Phone 717-243-2968 Fax 717-243-3639 "'i CD BARBARA STRAHOSKY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MICHAEL STRAHOSKY, : Defendant NO. 04-3098 CIVIL TERM ORDER OF COURT AND NOW, this 13`h day of July, 2007, upon consideration of Plaintiff's Motion To Compel Production of Pension Records by Defendant, a Rule is hereby issued upon Defendant, to show cause why the relief requested should not be granted. RULE RETURNABLE within 10 days of service. BY THE COURT, Warren Eth Certified Legal Intern Robert E. Rains, Esq. Thomas M. Place, Esq. Anne MacDonald-Fox, Esq. Lucy Johnston-Walsh, Esq. Megan Reismeyer, Esq. Supervising Attorneys Vamily Law Clinic 45 North Pitt Street Carlisle, PA 17013 Attorneys for Plaintiff \ Xubert X. Gilroy, Esq. 10 East High Street Carlisle, PA 17013 Attorney for Defendant rc 9 1 'Z [;1d G I 1E 1) LOR E-qo Barbara Strahosky, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Michael Strahosky, Defendant NO. 04 -3098 CIVIL TERM CERTIFICATE OF SERVICE I, Amy Bracher, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Petition to Make the Rule Absolute on Hubert X. Gilroy, Esq., attorney for Defendant Michael Strahosky, at 10 East High Street, Carlisle, PA 17013 by depositing a copy of the Petition in the United States mail, postage prepaid on this 17 day of March, 2008. Amy J)racher Certified Legal (Intern r1Vlu1? A A14 Anne MacTonald-Fox, es Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Barbara Strahosky, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DIVORCE Michael Strahosky, Defendant/Respondent NO. 04-3098 CIVIL TERM PETITION TO MAKE RULE ABSOLUTE AND NOW, comes Plaintiff Barbara Strahosky, by and through her attorneys, the Family Law Clinic, files this Petition to Make the Rule, issued on July 13, 2007, Absolute and states as follows: 1. On July 11, 2007, Barbara Strahosky filed a Motion to Compel Production of Pension Records by Defendant, Michael Strahosky. 2. A true and correct copy of Plaintiffs Motion to Compel Production of Pension Records by Defendant was served on Hubert X. Gilroy, Esq., Defendant's attorney, at 10 East High Street, Carlisle, PA 17013, by depositing a copy of the same in the United States mail, postage prepaid, on Wednesday, July 11, 2007. 3. On July 13, 2007, the Honorable J. Wesley Oler Jr. issued a rule upon Michael Strahosky directing him to show cause why the Motion to Compel should not be granted. 4. Twenty (20) days have passed and no response to the Rule has been filed by Michael Strahosky. Respectfully submitted, Date EI &U ?- A=O. Bracher Certified Legal Intern ,AAA(A, L. ROGER RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER KATE CRAMER-LAWRENCE Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Telephone: (717) 243-2968 Fax: (717) 243-3639 c-? c??, ? .?, . ?-" ? .Y..Yfi'_ =_ ....y ??? _ ? ' ? . = .? ?-? MAR 18 2008 Barbara Strahosky, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW DIVORCE Michael Strahosky, : Defendant No. 04 - 3098 CIVIL TERM ORDER OF COURT AND NOW, this Aday of M vel, 2008, a Rule to Show Cause having been issued and no response having been filed, it is hereby Ordered that Petitioner's Motion to Compel is granted. Michael Strahosky is hereby ordered to serve on plaintiff's counsel, the Family Law Clinic, full and complete records regarding his pension with Giant Supermarkets, a subsidiary of Ahold USA, within fie-(5? days of this order. 11i J.yesley Oler, J J _? ? ? ?-, . ,? .... ?: ??, ?..?. ?._ ? Lil - 4 7 ' ,a- ? , ` "? ti :t.? Y? ? i _ .. ?.? y"" ?.. ky1„ ?„? f^ 7 rJ??tt ? LJ ?. M Barbara Strahosky, Plaintiff V. Michael Strahosky, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE : NO. 04 - 3098 CIVIL TERM PRAECIPE TO WITHDRAW EQUITABLE DISTRIBUTION COUNT To the Prothonotary: Please withdraw the Count for Equitable Distribution (Count II) in the above-captioned matter filed in the Cumberland County Courthouse on July 2, 2004. 1 Date: cole Berman Certified Legal Intern A Lucy -Walsh Anne M Donald-Fox-- Thomas Place Robert Rains Megan Riesmeyer Supervising Attorneys The Family Law Clinic 45 N. Pitt Street Carlisle, PA 17013 (717)243-2968 Barbara Strahosky, Plaintiff V. Michael Strahosky, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE : NO. 04- 3098 CIVIL TERM CERTIFICATE OF SERVICE I, Nicole Berman, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Praecipe to Withdraw Equitable Distribution Count on Michael Strahosky, through his attorney of record, Hubert X. Gilroy, Esq., by depositing a copy of the same in the United States mail addressed to Martson Law Offices, 10 East High Street, Carlisle, Pennsylvania 17013 on June 4, 2008. /Z_ Nicole Berman Certified Legal LIem Meg 'esmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ?? ' - ?3 ; ?- ` , i . Gi? ;-? x Barbara Strahosky, Plaintiff V. Michael Strahosky, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 04 - 3098 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in September of 2003, and have continued to live separate and apart for a period of at least 2 years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I 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 unworn falsification to authorities. Date 28?? arbara Strahosky Plaintiff f't r.,, ?? c r-n. , ?? 1 ?? r- - ,?" ?? .. ???.^_. ?; ?. Barbara Strahosky, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Michael Strahosky, Defendant NO. 04 - 3098 CIVIL TERM CERTIFICATE OF SERVICE I, Nicole Berman, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code on Michael Strahosky, through his attorney, Hubert X. Gilroy, by depositing a copy of the same in the United States mail, postage prepaid, addressed to Hubert X. Gilroy, Esq., The Martson Law Offices, 10 East High Street, Carlisle, Pennsylvania 17013, on July 14, 2008. Nicole Berman Certified Legal Intern Anne WRTFonald-Fox, Esq Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ?C7_ _ 4'? ? r C'- i" ; s'i'-t? ?- .4- r^ s?- f 4 `i _ _: rsr, ? .. ?? ?:r? C Barbara Strahosky, Plaintiff V. Michael Strahosky, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE : NO. 04 - 3098 CIVIL TERM CERTIFICATE OF SERVICE I, Nicole Berman, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Notice of Intention to Request Entry of 3301(d) Divorce Decree on Michael Strahosky through his attorney of record, Hubert X. Gilroy, Esq., by depositing a copy of the same in the United States mail, postage prepaid addressed to Hubert X. Gilroy, Esq., Martson Law Office, 10 East High Street, Carlisle, Pennsylvania 17013 on August 4, 2008. Nicole Berman rtified Legal Intern G ' Anne d-Fox, Es Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ?tl 1 : ?.? C.. ,. ,1 t nJ ?- ._ . ?; f.., C.? ::. (?.. Barbara Strahosky, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Michael Strahosky, Defendant :NO: 04-3098 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after August 24, 2008, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Cr? co cv r Barbara Strahosky, Plaintiff V. Michael Strahosky, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04 - 3098 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown and separation for two years under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Personal service on Defendant at his place of business 255 South Spring Garden Street, Carlisle, PA 17013 on October 11, 2006 at 1:30 p.m. 3. (b) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: July 1, 2008; (a) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed and Served on July 14, 2008. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached: Service by first class mail on August 4, 2008. Date G? Nicole Berman Certified Legal Intern Robert ains, Esquire Lucy Johnston-Walsh, Esquire Anne MacDonald-Fox, Esquire Thomas M. Place, Esquire Megan Riesmeyer, Esquire Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 LU l (- ?. Lt- ( aN LL CID ? t ? ? F ._ ?y C-i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Barbara Strahosky, Plaintiff VERSUS Michael Strahosky, Defendant No. 2004 3098 DECREE IN DIVORCE AND NOW, <eWjr--,L3- D LC?Q IT IS ORDERED AND DECREED THAT Barbara Strahosky PLAINTIFF, Michael Strahosky AND DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE BY THE COU PROTHONOTARY 4;0? * p zv? -rp?g 5 a, -el or-? 4k -rQ -V, -r/