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Home My WebLink About05-1949 LAW OFFICES SNELBAKER & BRENNEMAN. P.C. RANDALL L. CLARK, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PE SYLVANIA Plaintiff v. TERRY D. CLARK, : NO. ('5./1)tlf CIVIL TER : CIVIL ACTION - LAW : IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims se 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 a ainst you by the Court A judgment may also be entered against you for any other claim or re ef requested in these papers by the Plaintiff. You may lose money or property or other rights im ortant to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown oft e marriage, you may request that the court require you and your spouse to attend marriage co nseling prior to a divorce decree being handed down by the court. A list of marriage counselor is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. ou are advised that this list is kept as a convenience to you and you are not bound to cho se a counselor from the list All necessary arrangements and the cost of counseling sessions arc 0 be borne by you and your spouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PR ERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT S GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHO OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. YOU DO ETHE Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013-3302 (717) 249-3166 SNELBAKER& BRENNEMAN, P. By: l~t11/Vl/L--- Attorneys for Plaintiff LAW OFFICES SNELBAKER & BRENNEMAN, P.C. RANDALL L. CLARK, IN THE COURT OF COMMON CUMBERLAND COUNTY, PE : NO. ,)S - '''14'1 CIVIL TER Plaintiff v. TERRY D. CLARK, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT COUNT I - DIVORCE 1. Plaintiff Randall L. Clark is an adult individual residing at 128 Holly nve, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant Terry D. Clark is an adult individual residing at 3543 Rolo 000, Mechanicsburg, Cumberland County, Pennsylvania. LEAS OF SYLVANIA 3. Both Plaintiff and Defendant have been bona fide residents of the Com 10nwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this omplaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on Septe ber 29,1996 in Las Vegas, Nevada. 5. There have been no prior actions of divorce or for annulment between tl e parties hereto in this or any other jurisdiction since the date of the marriage averred in P graph 4, above. 6. Neither party is a member of the armed forces of the United States of A enca. 7. The Plaintiff avers as the grounds upon which this action is based is th t the marriage between the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plai tiff may have the right to request that the Court require the parties to participate in counseling. 9. The parties have been living separate and apart since the first week of pril, 2003. 10. The Plaintiff requests this Court to enter a decree of divorce. WHEREFORE, Plaintiff Randall L. Clark requests this Court to enter a De ree of Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing tween the Plaintiff and Detendant. COUNT II - EQUITABLE DISTRIBUTION 11. Paragraphs I through 10, inclusive, of this Complaint are incorporated y reference herein. II. The Plaintiff and Defendant have legally and beneficially acquired prop rtyand debts during their marriage from September 29, 1996. 12. The Plaintiff and Defendant have not agreed as to any equitable distribut n of the marital property and debts. WHEREFORE, Plaintiff Randall L. Clark requests this Court to order equitab e distribution of marital property and debts. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. -2- LAW OFFICES SNELBAKER & BRENNEMAN, P.C. WHEREFORE, the Plaintiff requests this Court to: (a) enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony; (b) order equitable distribution of marital property and debts; a d (c) order such other relief as this Court deems just and reasona Ie. SNELBAKER, BRENNEMAN & SPARE P.C. 14~ Date: April 3, 2005 By: Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff Randall L. Clark -3- LAW OFFICES SNELBAKER & ~RENNEMAN, P.C. VERlFICA nON I verify that the statements made in the foregoing Complaint are true and co ect. I nderstand that false statements herein are made subject to the penalties of 18 Pa.C. . Section 904 relating to unsworn falsification to authorities. -- ate: if ~ 7v5 ~ dall L. Clark . , . . LAW OFFICES SNELBAKER & BRENNEMAN, P.C. RANDALL L. CLARK, IN THE COURT OF COMMON LEAS OF CUMBERLAND COUNTY, PE SYL VANIA Plaintiff v. NO. TERRY D. CLARK, Defendant CIVIL ACTION - LA W IN DIVORCE AFFIDA VII RANDALL L. CLARK being duly sworn according to law, deposes and ys: I. I have been advised of the availability of marriage counseling and und rstand that I ncy request thai rl-,\.:. <;01. (t require t:ur rny spouse and I pcl[ticipatt in counsehng. 2. I understand that the court maintains a list of marriage counselors in th Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require my spouse a I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties f] 8 Pa. C.S. 9 4904 relating to unsworn falsification to authorities. Date: Lf' 3-(\~ ~~u Randall L. Clark (Plaintiff) ~~," 1: ~. ....... - <:) I;;: l..", '1J ~ ...s'..:. ...... --. ~ t\, .... \l'>, 0", 'f,J -..t, . \ . \ ~~ ~~, \$ ~) ~ ~~ --. ~ '. , ~ ; t'>.... ~ \ V\ '0'''' ~ ~~' ~~ ,k t~ ~~, ~. 'l-- t ~~ ....t:.: ~, %> ',c",:::l Q c~> .... c '~~;; .-' :!'"'" ::r:.-r1. "C 1 ....7'~ rfl f- ,--' :0,\::3 _,J L c:) ~: .:"\f~l\ ~';~~--1~' , (2 ~~ - '~ 0' ----- SHERIFF'S RETURN - REGULAR CASE NO: 2005-01949 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CLARK RANDALL L VS CLARK TERRY D KENNETH GOSSERT , Sheriff or Deputy Sheriff of cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon CLARK TERRY D the DEFENDANT , at 2036:00 HOURS, on the 18th day of May at 3543 ROLO COURT 2005 MECHANICSBURG, PA 17055 by handing to TERRY CLARK a true and attested copy of COMPLAINT - DIVORCE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 8.14 .37 10.00 .00 36.51 r~~~ R. Thomas Kline 05/19/2005 SNELBAKER BRENNEMAN Sworn and Subscribed to before By: me this do tS day of !vi"""} ,,~ J.C:L-'~:/ A.D. ~ Jltu-- () ~ ~ 7 rothonotary Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDALL L. CLARK, v. Defendant : NO. 05-194l1f : CIVIL ACTION - LAW : IN DIVORCE CIVIL TERM TERRY D. CLARK, MOTION FOR APPOINTMENT OF MASTER Plaintiff moves this Court to appoint a master with respect to the following claims: (x) Divorce () Annulment () Alimony () Alimony Pendente Lite (x) Distribution of Property () Support () Counsel Fees () Costs and Expenses and in support of the motion states: (I) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The Defendant has appeared in the action by her attorney, Linda A. Clotfelter, Esquire. (3) The statutory ground(s) for divorce (is)(are): 330l(d), (4) Delete the inapplicable paragraph(s): (a) TRe aotisR is Ret esRtestea. (b) An agreement has been reached with respect to the following claims: None. (c) The action is contested with respect to the following claims: AIL (5) The action (iRyslves)(does not involve) complex issues of law or fact. (6) The hearing is expected to take 5 (Elays )(hours). (7) Additional infonnation, if any, relevant to the motion: None. Date: June 9, 2005 Vr~YYWL-- Keith O. Brenneman, Esquire Attorney for Plaintiff ORDER APPOINTING MASTER AND NOW, this day of Master with respect to the following claims: ,2005, E. Robert Elicker, II, Esquire is appointed BY THE COURT: J. (') c- :? --, i'5~- ~r" ('- :~~?-- f~ c - c.: 2: :::;! ...., = = "'" '- c:: ::;;:; ~ :r:n ,~ .~r- :0 o -<-, :]:--H ~O t::)rr, ;;j ::0 -< I U') .." ::i; N w a f (j RANDALL L. CLARK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA J q <</q : NO. 05-~ Plaintiff v. CIVIL TERM TERRY D. CLARK, Defendant CIVIL ACTION - LAW IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Plaintiff moves this Court to appoint a master with respect to the following claims: (x) Divorce () Annulment () Alimony () Alimony Pendente Lite (x) Distribution of Property () Support () Counsel Fees () Costs and Expenses and in support of the motion states: (I) Discovery is complete as to the claims(s) for which the appointment of a master is requested. (2) The Defendant has appeared in the action by her attorney, Linda A. Clotfelter, Esquire. (3) The statutory ground(s) for divorce (is)(are): 3301(d). (4) Delete the inapplicable paragraph(s): (a) The aetion is not coatested. (b) An agreement has been reached with respect to the following claims: None. (c) The action is contested with respect to the following claims: All. (5) The action (involves)(does not involve) complex issues of law or fact. (6) The hearing is expected to take 5 (tlays)(hours). (7) Additional information, if any, relevant to the motion: None. Date: June 9, 2005 v7~ Keith O. Brenneman, Esquire Attorney for Plaintiff ORDER APPOINTING MASTER ~~ AND NOW, this .I 1..) day of Master with respect to the following claims: obert Elicker, II, Esquire is appointed BY THE COURT: !?J. ~t;~ ~--------. -c' '1; l1~T, ~~t. r--:l = = GJ'1 C- c:::: z o " ~-n rnr -om :bC( 90 -rt' 0='] :?.:~ C) .--\ :r--..... :::0 .< I '-.0 -0 ~.. -- l'.'> W o ~ ~ % ~ :t 1'1"\ f?- -0\1:1 "00 ---, I C'.Q s::t C);J 7:, ff1 S Pr; ~ - v:> ~<"':~ .- .~~= -;r ::.=\ ~ ~ ~ _,(',0.. '-R (..1'\ c..n -------/------- t LAW OFFICES SNELBAKER & BRENNEMAN, P.C. RANDALL L. CLARK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 05-1949 CIVlL TERM TERRY D. CLARK, Defendant : CIVIL ACTION - LA W : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw Plaintiffs claim for equitable distribution raised in the Divorce Complaint and as a matter noted to be resolved by the Divorce Master with respect to the above- 'aptioned action. SNELBAKER & BRENNEMAN, P. C. pate: December 29, 2005 , BY:~ Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff Randall L. Clark ~ CERTIFICATE OF SERVICE L KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date, caused a true and correct copy of the foregoing Praecipe to be served upon the persons and in the manner indicated below: FJRST CLASS MAIL, POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Linda A. Clotfelter, Esquire 5021 East Trindle Road Suite 100 Mechanicsburg, P A 17050 E. Robert Elicker, II, Esquire 13 North Hanover Street Carlisle, PAl 70 13 ~ Keith O. Brenneman, Esquire SNELBAKER, BRENNEMAN & SPARE, P. e. 44 W. Main Street P. O. Box 318 Mechanicsburg, P A 17055 (717) 697-8528 Attorneys for Plaintiff Randall L Clark Date: December 29,2005 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. ------ C) ~ c;? ,: ~'.) cJ'" C) -on <-- :.E.':. I 0J ::;,: _.;,. - c.-.., :;:: - LAW OFFICES SNELBAKER & BRENNEMAN, P.C. II I' ANDALL L. CLARK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANIA Plaintiff v. NO. 05-1949 CIVIL TERM ERRY D. CLARK, Defendant C1VIL ACTION - LA W IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE L A complaint in divorce under Section 3301(c) of the Divorce Code was filed on pril 18, 21}05. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) ays have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to equest entry of the decree. 4. I verify that the statements made in this Affidavit are true and correct. I understand i Ihat false statements herein are made subject to the penalties of ] 8 Pa. C. S. S 4904, relating to nsworn falsdication to authorities. ate: / -{.>--d~ ~IJ/ 1( [,j Randall L. Clark, Plaintiff " C..) \i) ~ LAW OFFICES SNELBAKER & BRENNEMAN, P.C. ANDALL L. CLARK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 05-\949 CIVIL TERM ERRY D, CLARK, Defendant : CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. I 2. I understand that I may lose rights concerning alimony. division of property, lawyer's I , ees, or expenses if [ 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 nd that a copy of the decree will be sent to me immediately after it is filed with the rothonotary , 4. I verify that the statements made in this aftldavit are true and correct. I understand I hat false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to nsworn falsification to authorities. ate: j- 6 'Vr:J ~ /.tJ~ Randall L. Clark, Plaintiff ,-.----- 'c,~: ---- ""--0- LAW OFFICE,,-~ SNELBAKER & BRENNEMAN. P.C. RANDALL L CLARK, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 05-1949 C1V1L TERM TERRY D. CLARK, Defendant C1VIL ACTION - LA W IN DIVORCE DEFENDANT'S AFFlDA VlT OF CONSENT UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on April 18,2005. 2. The marriage of the Plaintiff and the Dcfendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of 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. 4. I verify that the statements made in this Affidavit are true and correct. I understand i' i that false statements herein are made subject to the penalties of 18 Pa. C. S. S 4904, relating to I f I'fi' h .. I,unsworn a Sl lcatJon to aut ontJes. I i Date: i / lo ' G r;; _ I \ . tcu/~ _~__ ~D. Clark, Defendant c~; c , " -'- Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANlA RANDALL L. CLARK, v. ; NO. 05-1949 CIVIL TERM TERRY D. CLARK, Defendant CIVIL ACTION - LAW IN DIVORCE r-<') .c':;:.:J . .~-' c-'. ;; 2;,,] DEFENDANT'S WAIVER OF NOTICE OF fNTENTlON TO REQUEST ENTRY OF A DIVORCE DECREE tINDER SECTION 330*) OF THE DIVORCE CODE c_ c.'" 1. I consent to the entry of a final decree of divorce without notice. (;.,? ~~\ ~.:: (.r. ~.::~ 2.. I understand that I may lose rights concerning alimony, division of pr<Jpert~ lav;yer's fees, or expenses if I do not claim them before a divorce is granted. II 3. J 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 witb the I Prothonotary. 4. J verify that the statements made in this affidavit are true and correct. I understand Date \, L" olo ~,~Mfc- . Terry D. Clark. Defendant that false statements herein are made subject to the penalties of 18 Pa. c.s. 9 4904 relating to unsworn falsification to authorities. LAW OFFICES SNELBAKER & BRENNEMAN. P.C. c , l.C. -.:-:1 C:::' RANDALL L. CLARK, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 05-1949 CIVIL TERM TERRY D. CLARK, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: by personal service on Defendant by the Sheriff of Cumberland County on May 18, 2005. 3. Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code: by the Plaintiff: January 6, 2006; by the Defendant: January 6, 2006. I . 4. Date of execution of Waiver of Notice in Section 330l(c) Divorce: by the Plaintiff: January 6,2006; by the Defendant: January 6, 2006. 5. Related pending claims: None. SNELBAKER & BRENNEMAN, P. e. Date: January 18, 2006 ~ By: Attorneys for Plaintiff LAW OFFICES SNELBAKER & BRENNEMAN, P.C. I I \ I , , i I I I i \ \ I I I I I I I,.. RANDALL L. CLARK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 05 - 1949 CIVIL TERRY D. CLARK, Defendant IN DIVORCE ORDER OF COURT AND NOW, this -N day of 2006, the economic claims raised in the proceedings havin~ withdrawn by praecipe filed on December 29, 2005, and the been parties having filed affidavits of consent and waivers of notice of intention to request entry of divorce decree, there being no matters, therefore, pending before the Master, the appointment of the Master is vacated. BY THE CClURT, P.J. cc: Aeith O. Attorney ~nda A. Attorney Brenneman for Plaintiff Clotfelter for Defendant o,o\D O\~ Iii' I u n I j, '_ 'l'''' :+. :+. +: :+ :f :f :f :f :f :f :+ :f :+; :f :f +: +: +: + +: +: . . . . . . . . . . . . . . . . +: +: +.:f + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++: + :f :+: :f +: :+ + 'l' :f + + +: ++++:+++++'+++++:+++:f++:++++:++++:++++:++++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +::f+:+::f+++:+:+++:++:f++:+:++:++'+++++:++++++:++'++++++~+++++++; ++'+'+'+'++++'+'++. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. RANDALL L. CLARK, No. 05-1949 CIVIL Plaintiff VERSUS TERRY D. CLARK, Defendant DECREE IN DIVORCE :~.:k IT IS ORDERED AND AND NOW, RANDALL L. CLARK DE:CREED THAT , PLAINTIFF, TERRY D. CLARK AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. / // \.t{)'\.../~ \v ~---- ~Tm~ik?4f.= ____ ' ~7 PROTHONOTARY '" - .. .. '?;1~'ll7 jir j!' /;/fn->-,- ;?~~~ "."'-t~-~J-? #?? f! -~v,y ~} ;P?? .. 7r.?- I " (, -7&?, C