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Home My WebLink About04-5891NANCY J. POWELL-COX, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 04- CIVIL TERM DAVID J. BROIDA, Defendant : IN DIVORCE PRAECIPE FOR WRIT OF SUMMONS TO: Curtis R. Long, Prothonotary Please issue a writ of summons against Defendant in the above-captioned matter. Date: November 23, 2004 Wayne. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 IV &"" J - PLIWr_'t(_ (?6'? 5 ? ? - f?ww1 v? E c 7Z I3 6 t av d.J7 ? r6id? r ?rf Avt- Jc v - 1 0 rr; ?•r: z N C= q wc N to -a Co J C1 -^C Commonwealth of Pennsylvania County of Cumberland NANCY J. POWELL-COX VS. DAVID J. BROIDA 8364 79th AVENUE Seminole FL 33777 Court of Common Pleas 04-5891 CIVIL No. ------------------------------------- 19 CIVIL ACTION - LAW In --------------------------------------------- David J. Broida: To ----------------------------------- You are hereby notified that Nancy J. Powell-Cox -------------------------------------------------------------------------------------------------- Summons -Civil Action - Law the Plaintiff has commenced an action in _-____-_----_ _ -- _______________________________ against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date November-23, ----------------- ---- CORTIS R. LONG ------------------------------------------------ Prothonota r By --- 7,c / De ut LI? i ? n I I ? ? W I 1 H r w 1 j a, I H ~' i o ? j I 1 o• r 1 I W ? ? I 1 I ? I 1 I 1 I ? ? 1 C1? d C H d 0 H d z z n K ro 0 ?z C+7 r r n O X O 1 'o i .P 1 1 i 00 1 F^' n H H r co I i NANCY J. POWELL-COX, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW V. NO. 04-5891 CIVIL TERM DAVID J. BROIDA, Defendant : IN DIVOR12E AFFIDAVIT OF SERVICE WAYNE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff in the above-captioned matter, that he did, on November 2.4, 2004, serve the Writ of Summons, Notice of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 and a copy of the Subpoena identical to the one that is intended to be served in the above-captioned matter upon Defendant by certified United States mail, postage prepaid, return receipt requested, addressee only, and that the same was received by Defendant on November 29, 2004, as evidenced by the return receipt card attached hereto bearing Certified No. 7033 3400 0018 5044 8578. It is understood that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: December 2, 2004 Wayn F. Shade WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 11%- • Complete items 1, 2, and 3. ,filets item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: D. Is delivery address different from item 13F u Ye' Mr. David J. Eroida H YES, enter delivery address below: 13 No 8364 79th Avenue Seminole, FL 33777-4217 3. Service Type MCertified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 2. Article Number 7099 3400 0018 5044 8578 (Transfer -from service label) PS Form 3811, August 2001 Domestic Return Receipt 14"".024""s (" ??a l J" .- • ;'j r,'i ,I ,r _...i - ? i i`i NANCY J. POWELL-COX, Plaintiff V. DAVID J. BROIDA, Defendant IN THE COUP:T OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : NO. 04-5891 CIVIL TERM : IN DIVORCE CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a Subpoena for documents and things pursuant to Rule 4009.22, Plaintiff certifies, as follows: 1. A Notice of Intent to Serve the Subpoena with a copy of the Subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the Subpoena is sought to be served. 2. A copy of the Notice of Intent, including the proposed Subpoena, is attached to this certificate. 3. No objection to the Subpoena has been received. 4. The Subpoena which will be served is identical to the Subpoena which is attached to the Notice of Intent to Serve the Subpoena. Date: December 22, 2004 Wayne F. hade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff NANCY J. POWELL-COX, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW V. NO. 04-5891 CIVIL TERM DAVID J. BROIDA, Defendant : IN DIVORCE NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff intends to serve a Subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the; Subpoena. If no objection is made, the Subpoena may be served. Date: November 24, 2004 ?-C/GGlr?.c.i /• ???C. Wayne F! Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 NANCY J. POWELL-COX, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 04-5891 CIVIL TERM DAVID J. BROIDA, Defendant : IN DIVORCE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Charles W. Carlson Director of Retirement Benefits Rite-Aid Corporation 30 Hunter Lane Camp Hill, Pennsylvania 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the court to produce the following documents or things at 53 'West Pomfret Street, Carlisle, Pennsylvania 17013: 1. Any and all documents in your possession or under your control related to the accrual of funds or other benefits in or disbursement of funds or other benefits from Account No. 340-28-3102, Plan No. 006742 (hereinafter "Broida's §401(k)") from January 1, 2000, through November 1, 2004. 2. Any and all documents in your possession or under your control disclosing or designating the names of any and all beneficiaries, heirs, spouses or other third parties with respect to Broida's §401(k) since January 1, 2000. 3. Any and all documents in your possession or under your control containing any reference to Nancy J. Cox, Nancy J. Cox-Broida, Nancy J. Broida, Nancy J. Powell-Cox, Nancy J. Powell or any variation thereof, including descriptive references such as David J. Broida's spouse or wife or her initials (all of which hereinafter "Plaintiff'). 4. Any and all documents in your possession or under your control showing, suggesting, disclosing, referencing or otherwise indicating Plaintiff s interest or lack thereof in Broida's §401(k). 5. Any and all documents in your possession or under your control evidencing, proving or tending to prove that Plaintiff has waived any :interest in Broida's §401(k). 6. Any and all documents in your possession or under your control requiring, bearing or purporting to bear Plaintiff s signature. You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the Certificate of Compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena within twenty (20) days after its service, the party serving this Subpoena may seek a court order compelling you to comply with it. Curtis R. Long Prothonotary office of the Protbonotarp Curnberlanb Cuuntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor ,?W- sa9l CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573