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HomeMy WebLinkAbout01-1396ERIC J. SNYDER, WENDY L. SNYDER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW : : NO. CIVIL TERM : IN DIVORCE NOTICE 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 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 the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 Phone: (717) 249-3166 ERIC J. SNYDER, Plaintiff Ve WENDY L. SNYDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO.O! . ' CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Eric J. Snyder, who currently resides at 125 Long Road, Cumberland County, Newville, Pennsylvania, since at least October, 1997. 2. Defendant is Wendy L. Snyder, who currently resides at Molly Pitcher Hotel, Cumberland County, Carlisle, Pennsylvania, since October 9, 1999. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaimiff and Defendant were married in April, 1996, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the fight to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. I verif~ that the statements made in this Complaint are tree and correct. 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: c- Eri~J. ~rnyder, Plaintiff Karl E. Rominger, Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 15,5 South Hanover Street Carlisle, Penns~lvanlct' 17013 717.241.6070 · 800.734.0&90 · FA,~/717.241.6878 www. romlngeriaw.¢om , law@romlngerlaw, com 1 North Mal~ Street Chambersburg, Pennsylvania 17201 ERIC J. SNYDER, Plaintiff V. WENDY L. SNYDER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAw IN DIVORCE NO. 01-1396 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Wendy L. Snyder, the Defendant in the above captioned matter. April 10, 2001 Katherine E. Bavo$o Certified Legal Intern THOMAS M. PLACE Supervising Attorney TERI HENNING Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 717/243-3639 ERIC J. SNYDER, Hainfiff V. WENDY L. SNYDER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LATM IN DIVORCE NO. 01-1396 CERTIFICATE OF SERVICE I, Katherine E. Bavoso, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of Praecipe to Enter Appearance on Karl E. Rominger, at 155 South Hanover Street, Carlisle, PA 17013, by depositing a copy of the same in the United States mall, First Class, postage prepaid, this 10* day of April, 2001. Certified Legal Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ERIC J. SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WENDY L. SNYDER : Defendant : CIVIL ACTION - LAW IN DIVORCE NO. 01-1396 PRAECIPE TO WITItDRAW APPEARANCE AND NOW, this / ~' day of December, 2001, the Family Law Clinic withdraws its appearance on behalf of the Defendont, Wendy L. Snyder. December I( ,2001 Respectfully submitted, t~ Certified Legal Intern THOMAS M. PLACE TERI L. HENNING SUPERVISING ATTORNEYS FAMILY LAW CLINIC 45 Noah Pitt Street Carlisle, PA 17013 717/243-2968 AND NOW, this II on behalf of the Defendant, Wendy L. Snyder. December ~ I ,2001 PRAECIPE TO ENTER APPEARANCE day of December, 2001, Thomas Flower, hereby enters his appearance Saidis, Shuff, Flower and Lindsay 2109 Market Street Camp Hill, PA 17011 717/737-3406 ERIC J. SNYDER, Plaintiff/Respondent VS. WENDY L. SNYDER, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2001 ~M-4, CIVIL TERM IN DIVORCE DR~ 31476 Pacses~ 617104276 ORDER OF COURT AND NOW, this 21st day of February, 2002, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby direc~l that the parties and their respective counsel appear before R.J. Shadda¥ on March 25, 2002 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: (1) 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 Mail copies on Petitioner 2-21-02 to: < Respondent Karl Rominger, Esquire Thomas Flower, Esquire Date of Order: February 21, 2002 ~'Shadday, Conference Officer ~"~,~_/ 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ERIC J. SNYDER, Plaintiff/Respondent VS. WENDY L. SNYDER, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA o~- ~3% F~- : CIVIL ACTION - LAW ' : NO. ~ CIVIL TERM : : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE Now comes WENDY L. SNYDER, by and through counsel, SAIDIS, SHUFF, FLOWER & LINDSAY, and petitions this Honorable Court as follows: 1. The parties hereto are husband and wife, having been joined in marriage on June 26, 1996, in Cumberland County, Pennsylvania. 2. The parties separated on or about October 9, 1999. 3. Petitioner is without the ability to earn income sufficient to meet her reasonable needs and to pay attorney's fees. WHEREFORE, Petitioner prays this Honorable Court to order alimony pendente lite in an amount equal to the Pennsylvania State Support Guidelines and reasonable attorney's fees. SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Defendant/Petitioner S.Ct. Id. ~3993 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 ERIC J. SNYDER, Plaintiff/Respondent VS. WENDY L. SNYDER, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 01 - '1396 .' : IN DIVORCE VERIFICATION I, Wendy L. Snyder, hereby verify that the statements made in the foregoing Petition are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ERIC J. SNYDER, Plaintiff/Respondent VS. WENDY L. SNYDER, Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 01 - 1396 : : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this /I~ day of February 2002, I, Thomas E. Flower, Esquire, of the fim~ of Saidis, Shuff, Flower and Lindsay, hereby certify that I this day served a true and correct copy of the Petition upon the party listed below via United States Mail, postage prepaid, addressed as follows: Karl E. Rominger, Esquire 155 So. Hanover Street Carlisle, PA 17013 Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY 'l'l~omas E Flower, Esquire Supreme Court ID #83993 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff · DR$ ATTACHMENT FOR APL PROCEEDINGS PETITIONER: DOB: ADDRESS: PHONE: ATTORNEY: WENDY L. SNYDER JULY 9, 1979 131 LIMEKILN RD., CARLISLE, PA 17013 (717) 249 - 4960 SAIDIS, SHUFF, FLOWER & LINDSAY PETITIONER'S EMPLOYMENT: HOW LONG? NET PAY: SHEIS CURRENTLY UNEMPLOYED SSN: 211 - 66- 3559 SHE HAS THE CAPACITY TO EARN MINIMUM WAGE FOR 20 HOURS PER WK. JOB TITLE: PRIOR EMPLOYMENT WAS AS CASHIER AT WEIS MARKET OTHER INCOME: (INCLUDEAMOUNTAND SOURCE) N/A RESPONDENT: ERIC J. SNYDER DOB: 01/20/72 SSN: 160-56-8659 ADDRESS: PHONE: ATTORNEY: NET PAY: JOB TITLE: 125 LONG ROAD, NEWVILLE, PA KARL ROMINGER, 155 So. HANOVER ST., CARLISLE RESPONDENT'S EMPLOYMENT: HOW LONG? PER MACHINIST OR METAL WORKER LANE ENTERPRISES OTHER INCOME: (INCLUDEAMOUNTAND SOURCE) OVERTIME AND/OR SECOND JOB WHEN MARRIED: 06/26/96 WHERE: CARLISLE, PA DATE SEPARATED: 10/09/99 WHERE LAST LIVED TOGETHER: 125 LONGS GAP RD., CARLISLE, PA FOR DRS INFORMATION ONLY In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ERIC J. sNyDER ¥$. WENDY L. SNYDER Plaintiff/Respondent Defendant/Petitioner ) Docket Number ) ) PACSES Case Number ) ) Other State ID Number 01-1396 CV 617104276 /D31476 ORDER AND NOW, to wit on this 4TH DAY OF APRIL, 2002 IT IS HEREBY ORDERED that the I~) Complaint for O Petition to Modify or O Other ALIMONY PENDENTE LITE REQUEST filed on FEBRUARY 12, 2001 in the above captioned matter is dismissed without prejudice due to: PETITIONER NOT SHOWING AN ENTITLEMENT TO ALIMONY pENDENTE LITE. O The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xc: plaintiff defendant Thcmas Flowsr, Esquire Karl Rominger, Esquire BY THE COURT: JUDGE Form OE-506 Service Type M Worker ID 21005 ERIC J. sNYDER, WENDY L. SNYDER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : :NO. 01 - 1396 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND ACKNOWLEDGEMENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 12, 2001,and I acknowledge receipt of a copy of the same, which was served on me on March 20, 2001, by Certified Mail. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 5. I have been advised of the availability of marriage counseling, and do not request that the Court require that my spouse and I participate in said counseling. 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 unsworn falsification to authorities. Sworn and subscribed to before me this W~ndy S~r, Defend~mt ERIC J. SNYDER, WENDY L. SNYDER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :NO. 01 -1396 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) _. COUNTY OF CUMBERLAND ) AND NOW, this 20~ day of May, 2002, I, Karl E. Rominger, Esquire, attorney for Eric J. Snydcr, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Divorce Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested, restricted delivery. The original return receipt card signed by the Respondent on indicating service was effected, March 20, 2001, is marked Exhibit "A", attached hereto and made a part hereof. Dated: May 20, 2002 By: ~ '~ Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 I.D. # 81924 · Complete Items 1, 2, and 3. AJso complete 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. / {Please Prfnt Clearly) Is daiivery ~ Rem1? r'l yes If YES, address below: i'-] No 4 Sewice Type ~'Certifled Mail [] Express Mail r-1 Registered ~'Return Receipt for Mer~ [] Insured Mail [] C.O.D. · Restricted Delivery? (Extra Fee) ._~Y# 2. Article Number (Copy from service label)_ _ o . PS Form 3811, July ~ Domestic Return Receipt 102595-00-M-0952 EXHIBIT "A" ERIC J. SNYDER, Ve WENDY L. SNYDER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : :NO. 01 -1396 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 12, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 unsworn falsification to authorities. Date: Eri~iff ERIC J. SNYDER, WENDY L. SNYDER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : :NO. 01 - 1396 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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. §4904, relating to unsworn falsification to authorities. Eric J. Snyder, Plaintiff ERIC J. SNYDER, WENDY L. SNYDER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : :NO. 01 - 1396 CIVIL TERM 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 § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail, March 20, 2001. 3. Date of execution of the affidavit of consent required by § 3301 (c) or The Divorce Code: by the Plaintiff May 13, 2002; by the Defendant May 13, 2002. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: May 20, 2002. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: May 20, 2002. Date: May 20, 2002 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ERIC J. SNYDER plaintiff VERSUS WENDY L. SNYDER Defendant NO. 01-1396 CIVIL ACTION DECree IN DIVORCE AND NOW, DECREED THAT AND ERIC J. SNYDER WENDY L. SNYDER ~_~-. IT iS ORDERED AND , PLAINTIFF, , 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 COUrt: PROTHONOTARY pa,