HomeMy WebLinkAbout04-3516
II
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
.
NO. t/~. 3Qk t4d
DAVID ALLEN WERTZ,
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 foregoing 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 in 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 the 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:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
II
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO.
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
NOTICE OF A V AILABILlTY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed
in the Court of Common Pleas of Cumberland County. This notice is to advise you that
in accordance with Section 3302 ld) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the
Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are
advised that this list is kept as a convenience to you and you are not bound to choose a
counselor from this list. All necessary arrangements and the cost of counseling sessions
are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling.
II
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO. 0 '{..- 35/'-
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, KAREN E. WERTZ, by his/her
attorney, Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is KAREN E. WERTZ, an adult individual who currently resides at
708 Carol Street in New Cumberland, Cumberland County, Pennsylvania.
2. The Defendant is DAVID ALLEN WERTZ, an adult individual who currently
resides at 126 North Locust Point Road in Mechanicsburg, Cumberland County,
Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing
of this Complaint.
4. The Plaintiff and Defendant were married on 10 June 1989 in New
Cumberland, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
II
COUNT II - EQUITABLE DISTRIBUTION
9. During the course of the marriage, the parties have acquired numerous items
of property, both real and personal, which are held in joint names and in the individual
names of each of the parties hereto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by
the Defendant, to equitably divide the property, both real and personal, owned by the
parties hereto as martial property.
COUNT III - ALIMONY
10. Plaintiff lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
11 . Plaintiff is unable to support herself in accordance with the standard of living
of the parties established during the marriage through appropriate employment.
12. The Defendant is employed and enjoys a substantial income from which he is
able to contribute to the support and maintenance of the Plaintiff and pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE. Plaintiff prays this Honorable Court to enter an Order awarding
Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate
to support and maintain Plaintiff in the station of life to which she has become
accustomed during the marriage.
COUNT IV - ALIMONY PENDENTE LITE
13. Plaintiff is without sufficient income to support and maintain herself during
the pendency of this action.
14. Defendant enjoys a substantial income and is well able to contribute to the
support and maintenance of Plaintiff during the course of this action.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her
reasonable alimony pendente lite during the pendency of this action.
COUNT V - COUNSEL FEES AND EXPENSES
1 5. Plaintiff is without sufficient funds to retain counsel to represent her in this
matter.
16. Without competent counsel, Plaintiff cannot adequately prosecute her claims
against Defendant and cannot adequately litigate her rights in this matter.
1,1
1 7. Defendant enjoys a substantial income and is well able to bear the expense of
Plaintiff's attorney and the expense of this litigation.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the
legal fees and expenses incurred by Plaintiff in this litigation of this action.
~
l. And
Attorney for Plaintiff
Supreme Court 10 # 1 7225
525 North 1 2'h Street
Lemoyne, Pa 1 7043
(717) 761-5361
II
I
I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of 18
Pa. C.S. 4904 (unsworn falsification to authorities).
Date:
7/11/0t.{
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KAREN E. WERTZ J--
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II
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
DAVID ALLEN WERTZ,
Defendant
NO. CLj- 35'/4-> b01
IN DIVORCE
MOTION FOR HEARING ON ALIMONY PENDENTE LITE
AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and
moves the Court for a conference at the Domestic Relations Office and an order awarding
her alimony pendente lite, based upon her claim for alimony pendente lite raised in the
divorce complaint filed in this matter contemporaneously with this motion. Attached
hereto and marked as Exhibit A is a copy of the divorce complaint raising that claim.
-
Dated: 2\ 0",", 2-O\)i.}
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO.
DAVID ALLEN WERTZ,
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 foregoing 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 in 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 the 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:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO.
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed
in the Court of Common Pleas of Cumberland County. This notice is to advise you that
in accordance with Section 3302 (d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the
Domestic Relations Office" 13 North Hanover Street, Carlisle, Pennsylvania. You are
advised that this list is kept as a convenience to you and you are not bound to choose a
counselor from this list. All necessary arrangements and the cost of counseling sessions
are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling.
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO.
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, KAREN E. WERTZ, by his/her
attorney, Samuel L. Andes, and makes the following Complaint in Divorce:
1 . The Plaintiff is KAREN E. WERTZ, an adult individual who currently resides at
708 Carol Street in New Cumberland, Cumberland County, Pennsylvania.
2. The Defendant is DAVID ALLEN WERTZ, an adult individual who currently
resides at 126 North Locust Point Road in Mechanicsburg, Cumberland County,
Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing
of this Complaint.
4. The Plaintiff and Defendant were married on 10 June 1989 in New
Cumberland, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE. Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
I
I
I
I
I
COUNT II - EQUITABLE DISTRIBUTION
9. During the course of the marriage, the parties have acquired numerous items
of property, both real and personal, which are held in joint names and in the individual
names of each of the parties hereto.
WHEREFORE. Plaintiff prays this Honorable Court, after requiring full disclosure by
the Defendant, to equitably divide the property, both real and personal, owned by the
parties hereto as martial property.
COUNT III - ALIMONY
10. Plaintiff lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
11. Plaintiff is unable to support herself in accordance with the standard of living
of the parties established during the marriage through appropriate employment.
12. The Defendant is employed and enjoys a substantial income from which he is
able to contribute to the support and maintenance of the Plaintiff and pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding
Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate
to support and maintain Plaintiff in the station of life to which she has become
accustomed during the marriage.
COUNT IV - ALIMONY PENDENTE LITE
13. Plaintiff is without sufficient income to support and maintain herself during
the pendency of this action.
14. Defendant enjoys a substantial income and is well able to contribute to the
support and maintenance of Plaintiff during the course of this action.
WHEREFORE. Plaintiff prays this Honorable Court to order Defendant to pay her
reasonable alimony pendente lite during the pendency of this action.
COUNT V - COUNSEL FEES AND EXPENSES
15. Plaintiff is without sufficient funds to retain counsel to represent her in this
matter.
16. Without competent counsel, Plaintiff cannot adequately prosecute her claims
against Defendant and cannot adequately litigate her rights in this matter.
17. Defendant enjoys a substantial income and is well able to bear the expense of
Plaintiff's attorney and the expense of this litigation.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the
legal fees and expenses incurred by Plaintiff in this litigation of this action.
L. And
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
;'
,
I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of 18
Pa. C.S. 4904 (unsworn falsification to authorities).
Date:
7/11/0t.{
t<~E.uJ~
KAREN E. WERTZ d--
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II
KAREN E. WERTZ,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO.
DAVID ALLEN WERTZ,
Defendant
IN CUSTODY
COMPLAINT IN CUSTODY
AND NOW comes the Plaintiff, KAREN E. WERTZ, by her attorney, Samuel L.
Andes, and makes the following Complaint for Custody:
1 . The Plaintiff is KAREN E. WERTZ, an adult individual who currently resides at
708 Carol Street in New Cumberland, Cumberland County, Pennsylvania.
2. The Defendant is DAVID ALLEN WERTZ, an adult individual who currently resides
at 126 North Locust Point Road in Mechanicsburg, Cumberland County, Pennsylvania.
3. The Plaintiff and Defendant are husband and wife.
4. The Plaintiff and Defendant are the parents of two minor children, Heather Renee
Wertz, born 20 December 1990, and Taylor Marie Wertz, born 9 August 1995.
5. Plaintiff seeks an award of shared legal custody of the minor children and an
award of primary physical custody of both girls to her.
6. The children were not born out of wedlock and at the time of this Complaint, the
children reside with both parents at the marital residence and in the joint legal and physical
custody of both parents.
7. During the past five years, the minor children have resided with the following
persons at the following addresses:
1998 - Early July 2004
126 North Locust Point Road
Mechanicsbur9, PA
Plaintiff & Defendant
Early July 2004 to present a. Heather has primarily resided
with the Defendant at126 North
Locust Point Road in
Mechanicsburg.
b. Taylor has primarily resided
with the Plaintiff at 708 Carol
Street in New Cumberland
8. The mother of the children is the Plaintiff who resides at the address set out
above. She is married to the Defendant.
9. The father of the children is the Defendant who resides at the address set out
above. He is married to the Plaintiff.
10. The Plaintiff is the natural mother of the children.
11. The Defendant is the natural father of the children.
12. The Plaintiff has not participated as a party or in any other way in any litigation
concerning the custody of the children in this or any other court.
The Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this or any other jurisdiction.
Plaintiff knows of no other person not a party to this action already who has physical
custody of or claims to have custody or visitation rights to the said children.
1 3. The best interests and permanent welfare of the children will be served by
granting the relief requested by Plaintiff for the following reasons:
A. Plaintiff has always been the primary care provider for both girls; and
B. Plaintiff, because of her temperament and her work schedule, is more
available to the girls to meet their emotional and other needs; and
C. Plaintiff is far better able to provide a wholesome and stable
environment for the girls in which they can grow into healthy young women;
and
D. An award of primary physical custody to her will serve the best
interest of both of the girls.
14. Each parent whose parental rights to the children have not been terminated and
the person who has physical custody of the children have been named as parties to this
action.
WHEREFORE, KAREN E. WERTZ, requests this Court to grant her custody of the
children,
~
el L. Ande
Attorney for Plaintiff
Supreme Court 10 # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
I verify that the statements made in this document are true and correct. I understand
that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904
(unsworn falsification to authorities).
Date:
7/1<1 loti
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Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO.
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
PETITION FOR EMERGENCY RELIEF
AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and
petitions the court for emergency relief, based upon the following:
1. The Petitioner herein is the Plaintiff, Karen E, Wertz. The Respondent herein is
the Defendant, David Allen Wertz.
2. During the marriage the parties acquired various marital assets which include:
A. The increase in value and the parties' personal financial investment
in the residence at 126 North Locust Point Road which was transferred by
Defendant's mother to Defendant during the marriage; and
B. An investment account in Defendant's name which contains the
proceeds of a 401 (k) Plan in his name from his former employment with
Appleton Paper Company, which account had a balance in mid June of
approximately $100,000.00; and
C. 401 (k) Plan and other retirement accounts in Plaintiff's name with
a value of approximately $25,000.00.
3. In early July of 2004, Defendant asked Plaintiff to move from the marital house
and, when she declined to do so, threatened to do injury to her pets. As a result of those
threats, fearing for the safety for her pets, herself and her children, Plaintiff moved from
the family home and took up a temporary residence with her mother in New Cumberland,
4. After Plaintiff moved from the marital residence, Defendant requested that she
return and, when she declined to do so, Defendant engaged in a course of conduct which
was intended to intimidate, terrorize and control Plaintiff. His actions included:
A. An attempt to lure and persuade both girls into living with him in
the hopes that Plaintiff would return to the family residence to be with the
children; and
"
B. Threats to destroy or discard her personal effects at the marital
residence; and
C. Stalking her at her mother's home and her place of employment;
and
D. Threatening to commit suicide himself if she did not return to the
marital residence.
As a result of this conduct, Plaintiff believes that DefE!ndant is obsessed with controlling
her and forcing her, against her will, to return to the marital residence and to his control.
5. During conversations she had with Defendant shortly after the parties'
separation, Defendant told Plaintiff that he was going to take various action to put marital
assets beyond her control and reach. The actions he threatened to take included:
A. Transferring the marital residence into his mother's name; and
B. Liquidating the account into which his Appleton Paper Company
401 (k) Plan proceeds were held and placing th,em in the control of other
parties; and
C. Otherwise disposing of various marital assets, or concealing them.
As a result of these threats and statements made by Defendant, Plaintiff believes that
Defendant will transfer assets, conceal assets, or take other actions to place assets
beyond her reach or control.
6. If Husband transfers or conceals the assets in accordance with his threats, there
will be insufficient other marital assets for this court to effect a fair or equitable division
of the marital assets and Plaintiff's rights to Equitable Distribution of the marital assets
will be lost or prejudiced.
WHEREFORE, Plaintiff prays this court to enter an order prohibiting Defendant from
transferring the marital residence, the investment account holding the 401 (k) Plan
proceeds, or transferring or concealing any other financial account or asset in his name or
under his control without further order of court.
~~.~
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
Ii
II
II
I verify that the statements made in this document are true and correct. I
understand that any false statements in this document are subject to the penalties of 18
Pa. C.S. 4904 (unsworn falsification to authorities).
Date:
711t..{ 10'1
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KAREN E. WERTZ,
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
Plaintiff
vs.
CIVIL ACTION - LAW
DA VID ALLEN WERTZ,
Defendant
NO. t/~ - 3-5:/4- ~
IN DIVORCE
ORDER OF COURT:
AND NOW this ;(\~ day of ~ ,2004, upon
c&Q~~t~n &.the ~e~~eti~..!i" E~~1!~~I~'4a-h?1b~~~OIlOWS;
~ . The Defendant David Alleiirwerta(~not transfer, conceal, encumber, or
otherwise dispose of his interest in the residence at 126 North Locust Point Road in
Mechanicsburg, Cumberland County, Pennsylvania, without further order of this court.
B. The Defendant David Allen Wertz shall not transfer, covert, encumber, or
otherwise dispose of any account or asset held with any financial institution, including,
but not limited to, the account holding the proceeds of his 401 (k) Plan with Appleton
Paper Company.
C. A hearing is hereby scheduled on Plaintiff's Petition, to be held before the
undersigned, in Court Room No. ~ of the Cumberland coun~se in Carlisle,
Pennsylvania, commencing at 1, .45 o'clock -EL.m. on the
)O(}... day of ~ ~ 2004....---.
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Distribution:
Samuel L. Andes, Esquire (Attorney for Plaintiff) (r i f~)
P.O. Box 168, Lemoyne, Pa 17043 _
~ 7_.}1-/)'I'
David Allen Wertz (Defendant) P Mf/o 0 C)h~'
126 North Locust Point Road, Mechanicsburg, A 17 5 r- .
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Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
fVl(!..~75 09';;';0&6z0/ ,
NO. ~tf- 3-576 ~
IN DIVORCE
DAVID ALLEN WERTZ,
Defendant
MOTION FOR HEARING ON ALIMONY PENDENTE LITE
AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and
moves the Court for a conference at the Domestic Relations Office and an order awarding
her alimony pendente lite, based upon her claim for alimony pendente lite raised in the
divorce complaint filed in this matter contemporaneously with this motion. Attached
hereto and marked as Exhibit A is a copy of the divorce complaint raising that claim.
Dated: 2\ \1~J1 2.{~.q_
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KAREN E. WERTZ,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO.
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
NOTICE TO DEFEND AND CLA.lM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in
the foregoing 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 in 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 the 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:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
Ij
KAREN E. WERTZ,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO.
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed
in the Court of Common Pleas of Cumberland County. This notice is to advise you that
in accordance with Section 3302 (d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the
Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are
advised that this list is kept as a convenience to you and you are not bound to choose a
counselor from this list. All necessary arrangements and the cost of counseling sessions
are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty days of the date on which you receive this notice. Failure to do so will
constitute a waiver of your right to request counseling.
KAREN E. WERTZ,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO.
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
COMPLAINT IN DIVOFlCE
AND NOW comes the above-named Plaintiff, KAREN E. WERTZ, by his/her
attorney, Samuel L. Andes, and makes the following Complaint in Divorce:
1 . The Plaintiff is KAREN E. WERTZ, an adult individual who currently resides at
708 Carol Street in New Cumberland, Cumberland County, Pennsylvania.
2. The Defendant is DAVID ALLEN WERTZ, an adult individual who currently
resides at 126 North Locust Point Road in Mechanicsburg, Cumberland County,
Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing
of this Complaint.
4. The Plaintiff and Defendant were married on 10 June 1989 in New
Cumberland, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court mquire the parties to participate in
counseling.
COUNT I - IRRETRIEVABLE BIREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE. Plaintiff requests this Court to enter a Decree in Divorce pursuant to
the Divorce Code of Pennsylvania.
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COUNT II - EQUITABLE DISTRIBUTION
9. During the course of the marriage, the parti'3s have acquired numerous items
of property, both real and personal, which are held in joint names and in the individual
names of each of the parties hereto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by
the Defendant, to equitably divide the property, both real and personal, owned by the
parties hereto as martial property.
COUNT III - ALlMO~1Y
10. Plaintiff lacks sufficient property to provide for her reasonable needs in
accordance with the standard of living of the parties established during the marriage.
11. Plaintiff is unable to support herself in accordance with the standard of living
of the parties established during the marriage through appropriate employment.
12. The Defendant is employed and enjoys a substantial income from which he is
able to contribute to the support and maintenance of the Plaintiff and pay her alimony in
accordance with the Divorce Code of Pennsylvania.
WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding
Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate
to support and maintain Plaintiff in the station of life to which she has become
accustomed during the marriage.
COUNT IV - ALIMONY PENDENTE LITE
13. Plaintiff is without sufficient income to support and maintain herself during
the pendency of this action.
14. Defendant enjoys a substantial income and is well able to contribute to the
support and maintenance of Plaintiff during the course of this action.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her
reasonable alimony pendente lite during the pendency of this action.
COUNT V - COUNSEL FEES ANlD EXPENSES
15. Plaintiff is without sufficient funds to retain counsel to represent her in this
matter.
16. Without competent counsel, Plaintiff cannot adequately prosecute her claims
against Defendant and cannot adequately litigate her ri<ghts in this matter.
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17. Defendant enjoys a substantial income and is well able to bear the expense of
Plaintiff's attorney and the expense of this litigation.
WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the
legal fees and expenses incurred by Plaintiff in this litigation of this action.
~~
Attorney for Plaintiff
Supreme Court 10 # 17225
525 Nortlh 12th Street
Lemoyne, Pa 17043
(717) 7131-5361
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I verify that the statements made in this Complaint are true and correct. I
understand that any false statements in this Complaint are subject to the penalties of 18
Pa. C.S. 4904 (unsworn falsification to authorities).
Date:
7/1'floLf
.
t<a~E.~
KAREN E. WERTZ
KAREN E. WERTZ,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND> COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
DAVID A. WERTZ,
Defendant/Respondent
NO. 2004-3516 CIVIL TERM
IN DIVORCE
Pacses# 092106',0 I
ORDER OF COURT
AND NOW, this 27th day of July, 2004, upon consideration of the attached Petition for Alimony
Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear
before R.I. Shaddav on Seotember 1.2004 at 9:00 A.M. for a conference. at 13 N. Hanover St., Carlisle.
PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be
entered.
YOU are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.11@
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT.
George E. Hoffer, President Judge
Date of Order: Julv 27, 2004
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YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. 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 MAY GET
LEGAL HELP.
<
Petitioner
Respondent
Samuel Andes, Esquire
Mail copies on
7-27-04 to:
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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KAREN E. WERTZ
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
04-3516 CIVIL ACTION LAW
DAVID ALLEN WERTZ
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, July 28, 2004
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before M"lissa P. Greevy, Esq. , the conciliator,
at 301 Market Street, Lemoyne, PA 17043 on Tuesday, August 31, 2004 at 10:30 AM
for a Pre-Hearing Custody Conference. At such conference, an eftort will be made to resolve the issues in dispute; or
ifthis cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COLlRT,
By: Isl
Melissa P. Greevy. Esq.
Custody Conciliator
mhc
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites 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.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY 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
Telephone (717) 249-3166
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO. () ~ -3.:5/&
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW this ~ day of August 2004, at the request and consent of
counsel for both parties, we hereby reschedule the hearing which had been scheduled for
August 10, 2004. The hearing will now be held before the undersigned, in Court Room 2
of the Cumberland County Courthouse at 1 :30 p.m. on September 29, 2004.
The terms of our prior order remain in effect until the date of that hearing.
BY THYOURT" A
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Distribution:
/Samuel L. Andes, Esquire (Attorney for Plaintiff)
P.O. Box 168, Lemoyne, Pa 17043
-Carol J. Lindsey, Esquire (Attorney for Dl~fendant)
26 West High Street, Carlisle, PA 17013
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DOMEsTIc RELATIONS SECTION
KAREN E. WERTZ ) Docket Number 04-3516 CIVIL
Plaintiff )
Ys. ) PACSES Case Number 092106601
DAVID A. WERTZ )
Defendant ) Other State In Number
AND NOW, to wit on this 1ST DAY OF SEPTEMBER, 2004
ORDER
ALIMONY PENDENTE LITE
ORDERED "'" "" 0 Co"",!>"" r", '""po" '" 0 _"" " Modify '" IV Oth"
IT IS HEREBY
matter is dismissed without prejudice due to:
THE PARTIES' INCOillES AND THE PENNSYLVANIA SUPPORT GUIDELINES.
filed on
07/21/04
in the above captioned
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petitioner.
DRO: RJ Shadday
xc: Plaintiff
defendant
Samuel Andes, Esquire
Carol Lindsay, Esquire
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JUDGE
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Worker ID 21005
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KAREN E. WERTZ,
PLAINTIFF
V.
DAVID WERTZ,
DEFENDANT
AND NOW, this
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
()'1 - '!f/Cp
: CIVIL TERM
ORDER OF COURT
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day of September, 2004, upon agreement of
counsel, the hearing scheduled for September 29, 2004, IS CANCELLED.
_,Samuel L. Andes, Esquire
For Plaintiff
vCarol Lindsay, Esquire
For Defendant
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KAREN E. WERTZ,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
DA VID ALLEN WERTZ,
Defendant
NO. 04-3516
IN CUSTODY
ORDER OF COURT
AND NOW this 1I-A- day of OcJ..crts2 ~ ,2004, upon the
agreement of the parties as evidenced by their attorneys' written stipulation, We hereby
order and decree as follows:
1. The Plaintiff Karen E. Wertz ("Mother") and the Defendant David Allen Wertz
("Father") shall share legal Custody, as defined by the law of Pennsylvania, of their two
minor children, Heather Renee Wertz, born December 20, 1990 and Taylor Marie Wertz,
born August 9, 1995.
2. Mother shall have primary physical Custody of the two children.
3. Father shall have such periods of temporary Custody or visitation as Father and
Mother may agree from time to time.
J.
Distribution:
..--samuel L. Andes, Esquire (Attorney for P/aintiff:1
P.O. Box 168, Lemoyne, Pa 17043
vCaro/ J. Lindsay, Esquire (Attorney for Defendant)
26 West High Street, Carlisle, Pa 17013
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Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
DA VID ALLEN WERTZ,
Defendant
CIVIL ACTION - LAW
NO. 04-3516
IN CUSTODY
ST/PULA T/ON
AND NOW lh;, 22J d.y of -s"'-L-, 1. . , 2004, lh, .bo,"
parties hereby stipulate and agree that the C~ter the attached Order to resolve
>h, m.tt,,, '""'ntiy ,'nding ;n >h;, "" ,"d to dm"m;n, lh, '"",ody of lh,k 'hUdmn.
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Attorney for Pla'firiff
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Karen E. Wertz
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David Allen Wertz
Plaintiff
OCT 1 2 2004;
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-3516 CIVIL TERM
CIVIL ACTION - LAW
KAREN E. WERTZ,
v.
DAVID ALLEN WERTZ,
IN CUSTODY
Defendant
ORDER TO RELINQUISH JURISDICTION
AND NOW, this 7th day of October, 2004, the parties haviing reached an agreement which
has been memorialized in a Stipulation and filed with this Court, the Conciliator hereby relinquishes
jurisdiction of the above captioned matter.
FOR THE COU~ ~
B~l~
Melissa Peel Greevy, Esquire
Custody Conciliator
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KAREN E. WERTZ,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. P'I_ j5'l(,
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW this day of , 2004, upon
consideration of Plaintiff's Petition, a hearing is hereby scheduled, to be held before the
undersigned in Court Room No. of the Cumberland County Courthouse in Carlisle,
Pennsylvania, commencing at o'clock .m. on
the _ day of 2004. Pending further order of court, Defendant
shall not remove, conceal, damage, destroy, or otherwise dispose of any of the tangible
personal property at the former marital residence at 126 North Locust Point Road in
Mechanicsburg, Pennsylvania.
BY THE COURT,
J.
Distribution:
Samuel L. Andes, Esquire (Attorney for Plaintiff)
P.O. Box 168, Lemoyne, Pa 17043
Carol J. Lindsay, Esquire (Attorney for Defendant)
26 West High Street, Carlisle, PA 17013
II
KAREN E. WERTZ,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY , PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. tJlf-~~51t,
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
PETITION FOR INTERIM RELIEF
AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and
petitions the court for interim relief, based upon the following:
1. The Petitioner herein is the Plaintiff, Karen E. Wertz. The Respondent herein is
the Defendant, David Allen Wertz.
2. The parties separated in August of 2004 at which time Plaintiff and the parties'
two minor children left the marital residence and took up a temporary residence with the
Plaintiff's mother in New Cumberland.
3. At the time she and the children moved from the marital residence, they left
almost all of their tangible personal property and personal effects in the house and took
only with them clothing and a few other small items.
4. Since the parties' separation, Defendant has taken several steps to divest
himself with marital assets or to otherwise place them beyond the control of Plaintiff or
this court. Those steps have included:
A. He transferred the residence from his name alone to the name of
his mother; and
B, He liquidated his retirement account and disposed of the cash
proceeds of that liquidation.
5. Defendant has refused to allow Plaintiff access to the residence which still
contains the furnishings and other tangible personal property of both Plaintiff and
Defendant and of their children. He has changed the locks and advised her that, because
she is not an owner of the property, she is not permitted to come to it.
6. Defendant has recently advised Plaintiff that he is going to dispose of many of
the items that remain in the house, including most of Plaintiff's personal effects and many
of the personal effects and belongings of the children. Defendant has threatened to place
some of those items outdoors and expose them to the elements where they will be
II
damaged or destroyed. Defendant has not specified how he will dispose of the other
items.
7. The parties' children live with Plaintiff and Plaintiff is now in the process of
obtaining long term housing for herself and the children. She needs the children's
possessions including, but not limited to, their furniture, clothing, and other items of
personal property, to provide a suitable home for the children.
8. Plaintiff also needs her reasonable share of the household furnishings owned by
the parties to make a comfortable home for herself and the children. Attached hereto,
and marked as Schedule A is a list of the items she wants from the house for that
purpose.
9. Plaintiff does not request this court make the final division of the marital assets
of the parties in this petition. Instead, she asks that the court award her possession of
the property that belongs to the children and of those items listed on Schedule A so that
she has them to make a suitable and comfortable home for herself and the children until
this action can be concluded.
10. Without the items Plaintiff requests, she cannot make a suitable home for
herself and the children and the parties' children will be innocent victims of the
Defendant's misconduct.
11. Defendant, by his conduct, has deprived Plaintiff and the parties' children of
their property and access to a reasonable portion of the marital property. His conduct
now threatens to destroy, remove, conceal, or otherwise dissipate those items. To
prevent loss of the property which belongs to Plaintiff and her children, Plaintiff requires
the intervention of this court.
WHEREFORE, Plaintiff prays this court to prohibit Defendant from disposing,
concealing, dissipating, damaging, or destroying any of the items of personal property
now in the marital residence without Plaintiff's consent and, after hearing, to award
possession to Plaintiff of the items of personal property which belong to the children and
of those items listed on Schedule A which is attached hereto.
s~~~Jv
Attorney for Plaintiff
Supreme Court 10 # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
II
CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the foregoing document upon counsel for
the Defendant by regular mail, postage prepaid, addressed as follows:
Carol J. Lindsay, Esquire
26 West High Street
Carlisle, PA 17013
Date: 9 November 2004
0J:~jth-~
seXl~ary for Samuel L. Andes
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I verify that the statements made in this document are true and correct. I
understand that any false statements in this document are subject to the penalties of 1 8
Pa. C.S. 4904 (unsworn falsification to authorities).
Date: 10 11.3 lot
XCUffl'- ( W 4
KAREN E. WERTZ J
Schedule A
MAPLE DINING ROOM SUITE GIVEN TO KAREN BY PARENTS
table with 2 extension leaves
four straight chairs
two captain chairs
one 2-piece hutch
all tablecloths (given by mother)
LIVING ROOM SUITE & LAMPS - DOWNSTAIRS FAMILY ROOM
green couch
green recliner
blue recliner (given by Karen's parents)
two green lamps
WHITE WICKER PORCH FURNITURE - DOWNSTAIRS INSIDE OF PORCH BESIDE
HOT TUB
couch with cushions
rocker with cushions
coffee table
silver TV with remote (downstairs inside of porch beside hot tub)
TV stand (downstairs inside of porch beside hot tub ) (wooden I swivel)
POOL ITEMS
Heather & Taylor's goggles
LAWN TABLE & CHAIRS WITH UMBRELLA
glass table
four chairs with tan flowered cushions
tan umbrella
KITCHEN
two pots
two pans
eight dinner plates dishes (white with black stripes)
eight dessert plates
eight cereal bowls
eight water glasses
eight highball glasses
one set of mixing bowls (3) clear with white design
Heather & Taylor's special glasses
mixer
utility spoons, forks & knives
Page 1 of 4
KITCHEN cont.
peering knife given by maternal mother
metal measuring spoons
spatula
set of salt & pepper shakers
storage bowls with lids
toaster
electric can opener
five t-towels
five dish cloths
spices
all candles
blender
glass cake pan
crock pot
cookie sheets
plastic spoons and rubber spatula
MISCELLANEOUS ITEMS
Christmas decorations in attic (yard ornaments, 3 piece reindeer, lights)
all handmade Christmas decorations made by Heather & Taylor
Halloween decorations in attic
Easter decorations in attic
snow blower (present to Karen from prior employer)
snow shovel in shed
leaf blower & mulcher (gift from father Ward)
garden hose
red tool chest on wheels and contents (deceased fathers)
ironing board in laundry room
clothes basket in laundry room
all personal items from deceased father and brother
garment bags
ten bath towels
ten hand towels
ten wash cloths
treadmill (gift from David)
yellow vaporizer (given my maternal grandmother)
VICK vaporizer
heating pad
DVD player& movies (gift from Dave)
All photos of Heather & Taylor
two bed blankets
two beach chairs
Page 2 of 4
MISCELLANEOUS ITEMS cont.
one broom
one trash can (outside by side of house)
all remaining personal items
one sweeper
one toaster oven
all original & copies of photos of myself taken by David Wertz
all original & copies of discs of myself taken by David Wertz
indoor grill
weed wacker
video tapes
suitcases
washer
box of yearbooks & photos
HEATHER'S BEDROOM FURNITURE & ALL PERSONAL ITEMS
headboard
frame
mattress & box spring
dresser with mirror
night stand
desk with chair
dictionary given by maternal grandmother
(All the above were given by maternal grandparents)
sheets, blankets and bedspreads that belong to Heather's bed
bed pillow
decorative pillows
rugs
pictures on wall and on dresser
lamps
jewelry
hamper
curtains at window & curtain road (silver decorative)
contents of desk
all remaining cloths & shoes (in bedroom & closet)
clothes packed away in attic
beach towels
sport bag
bikes
winter clothes
toys & games
Page 3 of 4
Computer with printer (given to Heather and Taylor by Father)
Computer desk with chair (given to Heather and Taylor by Father)
Heather & Taylor's computer games
Heather & Taylor's tapes
Heather & Taylor's movies
boom box
Karoke machine
TAYLOR'S BEDROOM FURNITURE AND ALL PERSONAL ITEMS
headboard
frame
mattress & Box spring
dresser with mirror
night stand
curio cabinet with all contents
(all the above were given by Maternal Grandparents)
sheets, blankets and bedspreads that belong to Taylor's bed
bed pillow
decorative pillows
pictures of penguins
penguin in dining room hutch (given by maternal grandmother)
floor lamp in Taylor's bedroom
jewelry
clothes that are packet away in attic
all remaining clothes, shoes & boots (in bedroom & closet)
all toys in bedroom
all toys in basement computer room closet
beads at bedroom door
books on shelf
beach towels
bikes
winter clothes
all penguins
Taylor's gingerbread house flower she made on hutch
penguin music box
Page 4 of 4
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Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY , PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO. ()'1-J~/(,
DAVID ALLEN WERTZ,
Defendant
IIN DIVORCE
ORDER OF COURT
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AND NOW this I ~ day of -,' \ lfWAJ ~_ , 2004, upon
,
consideration of Plaintiff's Petition, a hearing is hereby scheduled, to be held before the
undersigned in Court Room No. ~ of the Cumberland County C?urthouse in Carlisle,
Pennsylvania, commencing at C\_~) o'clock ~.m. on ~.j~
the 1 o{).,.- day of ~ 2004. Pending further order of court, fendant
shall not remove, conceal, damage, destroy, or otherwise dispose of any of the tangible
personal property at the former marital residence at 1261 North Locust Point Road in
Mechanicsburg, Pennsylvania.
J.
Distribution:
v&muel L. Andes, Esquire (Attorney for Plaintiff)
P.O. Box 168, Lemoyne, Pa 17043
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vCarol J . Lindsay, Esquire (Attorney for De'fendant)
26 West High Street, Carlisle, PA 17013
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Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO. CJCf-J5/t,
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
PETITION FOR INTERIM RE:L1EF
AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and
petitions the court for interim relief, based upon the following:
1. The Petitioner herein is the Plaintiff, Karen E. V't/ertz. The Respondent herein is
the Defendant, David Allen Wertz.
2. The parties separated in August of 2004 at which time Plaintiff and the parties'
two minor children left the marital residence and took up a temporary residence with the
Plaintiff's mother in New Cumberland.
3. At the time she and the children moved from the marital residence, they left
almost all of their tangible personal property and personal effects in the house and took
only with them clothing and a few other small items.
4. Since the parties' separation, Defendant has taken several steps to divest
himself with marital assets or to otherwise place them beyond the control of Plaintiff or
this court. Those steps have included:
A, He transferred the residence from his name alone to the name of
his mother; and
B. He liquidated his retirement account and disposed of the cash
proceeds of that liquidation.
5. Defendant has refused to allow Plaintiff access to the residence which still
contains the furnishings and other tangible personal property of both Plaintiff and
Defendant and of their children. He has changed the locks and advised her that, because
she is not an owner of the property, she is not permitted to come to it.
6. Defendant has recently advised Plaintiff that he is going to dispose of many of
the items that remain in the house, including most of Plaintiff's personal effects and many
of the personal effects and belongings of the children. Defendant has threatened to place
some of those items outdoors and expose them to the elements where they will be
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damaged or destroyed. Defendant has not specified how he will dispose of the other
items.
7. The parties' children live with Plaintiff and Plaintiff is now in the process of
obtaining long term housing for herself and the children. She needs the children's
possessions including, but not limited to, their furniture, clothing, and other items of
personal property, to provide a suitable home for the children.
8. Plaintiff also needs her reasonable share of the household furnishings owned by
the parties to make a comfortable home for herself and the children. Attached hereto,
and marked as Schedule A is a list of the items she wants from the house for that
purpose.
9. Plaintiff does not request this court make the final division of the marital assets
of the parties in this petition. Instead, she asks that the court award her possession of
the property that belongs to the children and of those itlems listed on Schedule A so that
she has them to make a suitable and comfortable home for herself and the children until
this action can be concluded.
10. Without the items Plaintiff requests, she cannot make a suitable home for
herself and the children and the parties' children will be innocent victims of the
Defendant's misconduct.
11. Defendant, by his conduct, has deprived Plaintiff and the parties' children of
their property and access to a reasonable portion of the marital property. His conduct
now threatens to destroy, remove, conceal, or otherwise dissipate those items. To
prevent loss of the property which belongs to Plaintiff and her children, Plaintiff requires
the intervention of this court.
WHEREFORE, Plaintiff prays this court to prohibit Defendant from disposing,
concealing, dissipating, damaging, or destroying any of the items of personal property
now in the marital residence without Plaintiff's consent and, after hearing, to award
possession to Plaintiff of the items of personal property which belong to the children and
of those items listed on Schedule A which is attached hereto.
j()Q~~
Sam L. Andes~
Attorney for Plaintiff
Supreme Court lID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the foregoing document upon counsel for
the Defendant by regular mail, postage prepaid, addressled as follows:
Carol J. Lindsay, Esquire
26 West High Street
Carlisle, PA 17013
Date: 9 November 2004
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Sedr tary for Samuel L. Andes
I verify that the statements made in this document are true and correct. I
understand that any false statements in this document are subject to the penalties of 1 8
Pa. C.S. 4904 (unsworn falsification to authorities).
Date: 10 11.3/0'{
Schedule A
MAPLE DINING ROOM SUITE GIVEN TO KAREN BY PARENTS
table with 2 extension leaves
four straight chairs
two captain chairs
one 2-piece hutch
all tablecloths (given by mother)
LIVING ROOM SUITE & LAMPS - DOWNSTAIRS FAMIIL Y ROOM
green couch
green recliner
blue recliner (given by Karen's parents)
two green lamps
WHITE WICKER PORCH FURNITURE - DOWNSTAIRS n~SIDE OF PORCH BESIDE
HOT TUB
couch with cushions
rocker with cushions
coffee table
silver TV with remote (downstairs inside of porch beside hot tub)
TV stand (downstairs inside of porch beside hot tub) (wooden / swivel)
POOL ITEMS
Heather & Taylor's goggles
LAWN TABLE & CHAIRS WITH UMBRELLA
glass table
four chairs with tan flowered cushions
tan umbrella
KITCHEN
two pots
two pans
eight dinner plates dishes (white with black stripes)
eight dessert plates
eight cereal bowls
eight water glasses
eight highball glasses
one set of mixing bowls (3) clear with white design
Heather & Taylor's special glasses
mixer
utility spoons, forks & knives
Page 1 of 4
KITCHEN cont.
peering knife given by maternal mother
metal measuring spoons
spatula
set of salt & pepper shakers
storage bowls with lids
toaster
electric can opener
five t-towels
five dish cloths
spices
all candles
blender
glass cake pan
crock pot
cookie sheets
plastic spoons and rubber spatula
MISCELLANEOUS ITEMS
Christmas decorations in attic (yard ornaments, :3 piece reindeer, lights)
all handmade Christmas decorations made by Heather & Taylor
Halloween decorations in attic
Easter decorations in attic
snow blower (present to Karen from prior em plover)
snow shovel in shed
leaf blower & mulcher (gift from father Ward)
garden hose
red tool chest on wheels and contents (deceased fathers)
ironing board in laundry room
clothes basket in laundry room
all personal items from deceased father and brother
garment bags
ten bath towels
ten hand towels
ten wash cloths
treadmill (gift from David)
yellow vaporizer (given my maternal grandmother)
VICK vaporizer
heating pad
DVD player& movies (gift from Dave)
All photos of Heather & Taylor
two bed blankets
two beach chairs
Page 2 of 4
MISCELLANEOUS ITEMS cont.
one broom
one trash can (outside by side of house)
all remaining personal items
one sweeper
one toaster oven
all original & copies of photos of myself taken by David Wertz
all original & copies of discs of myself taken by David Wertz
indoor grill
weed wacker
video tapes
suitcases
washer
box of yearbooks & photos
HEATHER'S BEDROOM FURNITURE & ALL PERSONAL ITEMS
headboard
frame
mattress & box spring
dresser with mirror
night stand
desk with chair
dictionary given by maternal grandmother
(All the above were given by maternal grandparents)
sheets, blankets and bedspreads that belong to Heather's bed
bed pillow
decorative pillows
rugs
pictures on wall and on dresser
lamps
jewelry
hamper
curtains at window & curtain road (silver decorative)
contents of desk
all remaining cloths & shoes (in bedroom & closet)
clothes packed away in attic
beach towels
sport bag
bikes
winter clothes
toys & games
Page 3 of 4
Computer with printer (given to Heather and Taylor by Father)
Computer desk with chair (given to Heather and Taylor by Father)
Heather & Taylor's computer games
Heather & Taylor's tapes
Heather & Taylor's movies
boom box
Karoke machine
TAYLOR'S BEDROOM FURNITURE AND ALL PERSONAL ITEMS
headboard
frame
mattress & Box spring
dresser with mirror
night stand
curio cabinet with all contents
(all the above were given by Maternal Grandparents)
sheets, blankets and bedspreads that belong to Taylor's bed
bed pillow
decorative pillows
pictures of penguins
penguin in dining room hutch (given by maternal grandmother)
floor lamp in Taylor's bedroom
jewelry
clothes that are packet away in attic
all remaining clothes, shoes & boots (in bedroom & closet)
all toys in bedroom
all toys in basement computer room closet
beads at bedroom door
books on shelf
beach towels
bikes
winter clothes
all penguins
Taylor's gingerbread house flower she made on hutch
penguin music box
Page 4 of 4
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KAREN E. WERTZ,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DAVID ALLEN WERTZ,
DEFENDANT
04-3516 CIVIIL TERM
ORDER OF COURT
AND NOW, this
~
day of December, 2004, upon agreement of
counsel, the hearing on the plaintiff's petition for emergEmcy relief currently scheduled
for December 10, 2004, IS CONTINUED GENERALLY to be rescheduled at the
request of either party.
By the Court,
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Edgar B.
fiamuel L. Andes, Esquire
For Plaintiff
~arol J. Lindsay, Esquire
For Defendant
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO. 0'1- 35:/ (.. Cu.;' C/~ "I
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please withdraw the Petition for Interim Relief filed by the Plaintiff in this matter on
1 2 November 2004,
7 January 2005
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Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
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KAREN E. WERTZ, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
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vs. ) CML ACTION - LAW
)
) NO. 2004-3516 CIVIL
DAVID ALLEN WERTZ. )
Defendant ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 21
July 2004 and served on or about 22 July 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301{c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees, or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Gf/Q()!OU
Dated:
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KAREN E. WERTZ
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KAREN E. WERTZ, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
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vs. ) CML ACTION - LAW
)
) NO. 2004-3516 CML
DAVID ALLEN WERTZ, )
Defendant ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 21
July 2004 and served on or about 22 July 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees, or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S.. Section 4904
relating to unsworn falsification to authorities.
CI/Qo/OLJ
Dated:
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DAVID ALLEN WERTZ'
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2004-3516 CML
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I, David Allen Wertz, hereby accept service of the Divorce Complaint and
acknowledge receipt of a copy of the same on or about July 25, 2004.
25 July 2004
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DAVID ALLEN WERT .
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Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
KAREN E. WERTZ,
vs.
CIVIL ACTION - LAW
NO. 2004-3516
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301 Ie).
2. Date and manner of service of the Complaint: Acceptance of Service filed bv Plaintiff's
counsel indicatinQ service on or about 22 Julv 2004.
3. Complete either Paragraph (a) or Ib):
la) Date of execution of the Affidavit of Consent required by Section 3301
(c) of the Divorce Code: By Plaintiff: 20 September 2006 By Defendant: 20
September 2006
Ib) (1) Date of execution of the Affidavit required by Section 3301 Id) of the
Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit
upon the Respondent:
4. Related claims pending:
None.
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is
attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 Ie) Divorce was filed
with the Prothonotary; Dated 20 September 2006, filed contemporaneouslv
herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed
with the Prothonotary: Dated 20 September 2006. filed contemporaneouslv .
herewith.
Date: 20 September 2006
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IN THE COURT OF COMMON PLEAS :
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
KAREN E. WERTZ~
Plaintiff
No.
2004-3516
VERSUS
DAVID ALLEN WERTZ~
Defendant
DECREE IN
DIVORCE
AND NOW,
Od'D b <A- ,;2..0 ,.
KAREN E. WERTZ
2006
, IT IS ORDERED AND
DECREED THAT
, PLAI NTI FF,
DAVID ALLEN WERTZ
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;
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BY THE COUR4 ~
OTHONOTARY
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
qOUNTY, PENNSYLVANIA
dML ACTION - LAW
KAREN E. WERTZ,
Plaintiff
NO. 2004-3516 CIVIL
DAVID ALLEN WERTZ,
Defendant
IN DIVORCE
NOTICE TO RESUME PRIOR ~URNAME
NOTICE IS HEREBY GIVEN that KAREN E. WERT~, Plaintiff in the above matter,
having been granted a Final Decree in Divorce on the 0 (11:) ~ete. 2.0 ~ 2006, hereby
elects to resume the prior surname of KAREN E. MARTIN], and gives this written notice
pursuant to the provisions of 54 P .S. ~ 704.
Date:
/6 ~ JOl;
iXcuuJ W4
KAIlliN E. WERTZ
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KAlllliN E. MARTIN
COMMONWEALTH OF PENNSYLVANIA
)
( SS.:
COUNTY OF CUMBERLAND )
On the Z3r8-- day of () ~€i<- ,2006, before me, the undersigned officer,
personally appeared KAREN E. WERTZ, known to me (ot satisfactorily proven) to be the person
whose name is signed to the within Notice to Resume Pr~or Surname and acknowledged that
she executed the foregoing for the purpose therein conta ned.
IN WITNESS WHEREOF, I hereunto set my hand nd official seal.
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Notary PublIC.
NOTARIAL SEAL
LYNN EHRENFELD. NOTARY P\8JC
LEMOYNE IORO.. w~.,co.
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