HomeMy WebLinkAbout93-3346 t
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ROBIN K. CREEK,
r IN THE COURT OF COMMON PLEAS of
Plaintiff PERRY COUNTY, PENNSYLVANIA.
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va, CIVIL ACTION — LAM
s
DOUGLAS E. CREEK, = NO. 33S��c CIVIL 1993
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Defendant s IN DIVORCE
IIO'I'ICF"r0 ,P;N�)Ah'D C M RIC"r-;p
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 grounds for divorce is indignities or irretrievable breakdown of the marriage,
YOU may request marriage counselling. A list of marriage counselor- is available in the
Prothonotary's Office at the Cumberland County Courthouse,Carlisle,Pennsylvania,
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DI'+'lSION OF PROPERTY,
LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE R=GH'I'TO CLAIM ANY OF THE::%i.
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 STET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Central Pennsylvania Ugal Services
North Carlisle Street
New Bloomfield,PA 17068
` Telephone (717) 582-41.71
James J.Kayer,Esquire
Attorney for Plaintiff
Fifty.Fast High Street
Carlisle,PA 17013
(717) 243-7922
-7777*
ROBIN K.CRi!:EY, IN THE<OUXI'Of COMMON PLEAS OF
Plaintiff' PERRY COUNTY,PENNSYLVANIA
vs. CIVIL AC ON-LAW
DOUGLAS E.CREEK, NO. CML 1998
Defendant IN DIVORCE
MPLAAINT IN DIVORCE
COMES NOW, Plaintiff ROBIN K. CREEK, through her attorney, James J. Kayer,
Esquire and avers as follows:
COUNT I — DIVORGF
i. Plaintiff is Robin K. Creek, whose current residence is 108-G Perry Manor,
Newport,Perry County,PA 17074.
2. Defendant is Douglas E. Creek, whos4-� address is 542nd Maintenance
Company,ft.Lewis,Washington 98444.
8. Plaintiff and Defendant have been bona fide re dents of the Commonwealth for
at least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on July 21, 1985 in Hardin,Kentucky.
5. There has been no prior actions of divorce wed in this,matter.
6. The marriage is irretrievably broken, and the parties are pr --eding under
Section 881.ri(c) of the Divorce Code.
7. Defendant is zn active member of the United States Armed forces.
WHEREFORE,Plaintiff requests the court to enter a decree of divorce.
Respectfully submitted,
es er, uire
East h Street
rl;slc, .1 A 1701.8
4(717) 248-7922
VERIFICATION OF PLEADINGS
I verify that the statements made in this document are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. -,-,ction 4904, relating to
unsworn falsification to authorities.
Date:
R01 IN K. CIZEEX, : IN 'I'H1:: C'OUR"I' (,)F CCOMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL ACTION - LAW
NC). 3346 CIVIL T RM 1993
DOUGLAS E. CREEK,
Defendant : IN DIVORCE
AMENDED COMPLAINT
IN DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE
COMES NOW, Plaintiff ROBIN K. CREEK, through her attorney, Jaynes J. Kayer, Esquire
and avers as follows:
COUNT 11 - DIVORCE
1. Plaintiff is ROBIN K. CREEK, who resides at 103 G Perry Marcor, Apartment G-3,
Newport, Perry County, Pennsylvania 17074.
2. Defendant is DOUGLAS E. CREEK, who resides at 584th Maintenance Co., Ft.
ampbell, Kentucky 42223,
3. Plaintiff and Defendant have been bona tide residents of the Com rrionwealth for at least
six tnonths immediately previous to the tiling of this Complaint.
4. The Plaintiff and Defendant were married on July 21, "'u5 iri Hardin, K mucky.
5. There have been no prior actions of divorce filed in ..,iter.
6. Defendant is an active member of the United States Armed Forces.
7. The marriage is irretrievably broken, and the parties are proceeding i k er Section 3301(d)
of the Divorce. Code.
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/ WHEREfR I ma!! mR requests the court to enter a decree Of, ±wrce,
Respectfully subs mit¢
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VERIFICATION ATION OF PLFIADINGS
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The forvvOiaag da>caatneaat i, brie(( talaou info rmatiota Which has bean gathered by lily
counscl and myself in the: preparation of this action. The laaagutage of the doctatraent naay, ill part,
I
Int• the language cat ally counsel and not Illy owra. 1 have read the statements rraacle it) this
deiclament and to the extent that it is basso.% 'Won information winch I have given to arty coua><sel,,
it is true and correct to the I-W,t of lily knowledge, ittforrnatioll and belief. To the extent that the
contents of the Statements are that of cc�tuasel, 1 have relicel upon courasc;l ill making tfais
Verif'icatiora. I understand that talse state.rraents herein are made stabject to tilt.peraaltics of 18 PA.
C.S. § 4904, relating to unsworn talsificratioaa to authorities.
CERTIFICLkTE OF SEgVICE
1 hereby certify t}rat a True cc py of tyre foregoing Notice and C;01nplaint in Divorce was served
,n Defendant, by First class mail, Postage prepaid, by forwarding a true and correct copy unto:
Douglas E. Creek
C/O C:()MM. cling Officer
584th Maintenance Company
Ft. C:antphell, KY 422.23
r
Elated: 1(/26- 1996
1arn .if 1. Kay , Fs
Liboy 1-0
4 L,, 'rty Avenue
:`'Iirlisle, PA 17013
(717) 243.7:122
ROBIN K, CR11,1K, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL. AC71ON - LAW
NO, 3346 CIVIL. TERM 1993
DOUGLAS E. CREEK,
Defendant : IN DIVORCE
d
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU NAVE 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 'nay lose money or property or other rights important to you, including custody or
visitation of your children. y
When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counselling. A list of marriage counselors is available in the Prothonotary's Office at
tt'u Cumberland County Courthouse, Carlisle, Pennsylvania.
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 IOU CAN GET LEGAL HELP.
Court Administrator - Fourth Floor
Cumberland County Courthouse
Carlisle, Penn:ylvajli�1 ;`(113
Telephone (717) 240-6200
.lames J. Kayer, Esquire
Attorney for Plaintiff
ui berty Loft
4 East Liberty Avenue
Carlisle, PA 17013
(717) 243-7922
ROBIN K. CREEK, : IN THE COURTOF COMMON FLEAS OF
Plaintiff CUMBERLAND CC)UNTY, PENNSYLVANIA
z
vs, : CIVIL AC 11ON - LAW
DOUGLAS E. GREEK, NO. 3346 CIVIL TERM 1993
Defendant : IN DIVORCE
AMENDED COMPLAINT
IN DIVORCE UNDER SECTION 3301(4) OF THE DIVORCT COBE
COMES NOW, Plaintiff ROBIN K. CREEK, through her attorney, Jaynes J. Kayer, Esquire
and avers as follows:
COUNT I - DIVORCE
1. Plaintiff is ROBIN K. CREEK, who resides at 103 G Perry Manor, Apar,ment G-3,
Newport, Perry County, Pennsylvania 17074,
2Defendant is DOUGLAS E. CREEK, vho resides at 584th 'Maintenance Co., Ft.
Campbell, Kentucky 42223,
a. Plaintiff Inas been a bona fide resident of the COMIT1011weaith for at least six months
immediately previous to the filing of this Corr)plaint.
4. The Plaintiff and Defendant were married on July 21, 1985 in Hardin, Kentucky.
T"dere have been no prior actions of divorce filed in this niatter.
6. Defendant is an active inember of the United States Armed Farces.
7. The marriage is irretrievably broken, tend the parties are proceeding under Section 3301(d)
of the Divorce Cade.
WHEREFORE, Plaintiff requests the c�rurt to enter a decree of divorce.
COUNT 11 - Fou, vAni v DISTRIBU' ION
8. Paragraphs .I through 7 are incorported herein as though stated in fell,
9. During the tnarriage, the parites acculnulated certain real and persolial property which is
subjec t to distribution.
WHEREFORE, Plaintiff prays this Honorable Court to equitably distribute the marital
property.
Respectfully subinitted,
1
1 `
Jam K,' er, .quire
Lib�e y Lo
4 LJi ny enut
C'alli 4e, P 17013
(71 243-7922
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ROBIN K. CREEK, : III THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
NO. 3346 CIVIL TERM 1993
DOUGLAS E, CREEK,
Defendant ; IN DIVORCE
OR LER OF COURT
AND NOW,this 3d y of are1996,}a on consideration
P of the within petition for Bifurcation
and upon motion of James J. Kayer, Esquire, attorney for the Plaintiff, a rule is issued upon the
Defendant, Douglas E. Creek to show cause why these divorce proceedings should not be bifurcated and
a Decree in Divorce entered with reservation of jurisdiction over the economic issues.
Rule returnable within a days of date of service hereof.
BY 'iHE COURT,
cc: James J. Kayer, Esquire
Attorney for Plaintiff
Douglas Creek,pro se
j84th Maintenance Co.
Ft. Campbell, KY 42223
TRUE COPY FROM RECORD
In �xst�m�o y l Fr:rGaf,. ! f,�ra ,,,
and ile seal of said Cert at Car! C, r'a.� hand
day uf... 19.ya,
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ROBIN K. CREEK,
Its THE COURT OF COMMON PLEAS O
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 3346 CIVIL TERM 1993
DOUGLAS E. ('REEK,
Defendant : IN DIVORCE
DR OF COURT
AND NC)V4', ttiiv/ ddy Of l r. 99fi, upon consideration of the within
petition for Bifurcation
and upon motion of James J. Kayer, Esquire, attorney for the Plaintiff, a rule is issued upon the
Defendant, Douglas E. Creek to show cause why these divorce proceedings should not be bifurcated and
a Decree in Divorce entered with reservation of jurisdiction over the economic issues.
Rule returnable within days of date of service hereof.
PYT C()URT,
------- -___-- _
cc: James J, Kayer, Esquire
Attorney for Plaintiff ( J
Douglas Creek,pro se Vi
584th Maintenance Co.
Ft. Campbell, KY 42223
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ROBIN K. CREEK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff ; CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL., ACTION LAW
NO, 3346 CIVIL TERM 1993
DOUGLAS E. CREEK,
Defendant : IN DIVORCE
PETITION FUR Fail~U.RCATLON -o,,
M
COMES NOW, Plaintiff ROBIN K. CP.EEK battorney
F c�
y and through her attorneyes J: Kaye
Esquire, who re
4 respectfully represents as follows:
1. Plaintiff, Robin K. Creek, is an adult individual who resides at 103 G. Perry Manor,Apt G-3,.%-'-v%
Newport, Perry County, Pennsylvania, 17074.
2. Defendant, Douglas E. Creek, is an adult individual who last known address was 584th
Maintenance Co., Ft. Campbell, Kentucky, 422^7.
3. On or about October 21, 1993 the Plaintiff filed a Complaint. in Divorce allef*ing that tl e
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marriage was irretrievably broken.
4. Defendant, who is pro se, has not filed any Answer or other responsive pleading.
5. Previously, the .Plaintiff has fled her Affidavit under Section 3301(d) of the Divorce Code.
6. To date, the Defendant has not filed the Defendant's C .iteraffidavit since it was served on
him.
7. Plaintiff believes and therefore avers that Defendant would not be pr,:judiced by entry of a
bifurcated Decree in Divorce after nearly three years of separation from marital cohabitation.
3,
WHEREFORE, Plaintiffs respectfully requests that your Honorable Court issue a Rule upon the
Defendant to show cause why a bifurcated Decree in Divorce with reservation to the economic issues
should not be er,-,ered.
Respectfully submitted,
jUrty
J. j
, E uire
ue Le, 7013
( 243
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VFRiFIC'ATIQN OF PLFADINI
The foregoing docum-nt is based upon information which has been gathered by my
counsel and myself in the preparation of this action. The language of the document may, in
part, be the language of my counsel and not my own. I have read the statements made in this
document and to the extent that it is based upon information which I have given to my
counsel, it is true and correct to the best cit my knowledge, information and belief To the
extent that the contents of the statements are that of counsel, I have relied upon counsel in
making this Verification. 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: _, 1996 —�� .
k0BIN K, C REL:K,
Plaintiff
IN I'HI: COUkT OF COMMON PLEAS OFCUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
DOUGLAS E- (:`REEK, No , 3346 CIVIL. TERM 1993
Defendant IN DIVORCE
UR- j
ANI) NOW, this '"'"_mm` c►st" day of Au 199, ►pon co►►,ideratio r, of the within Petition and upon
motion of 1anjes J. Kayer, the att«r►tey for the Plaintiff, the Petition for Bifur , .
cation o the above-
captioned Matter is hereby granted.
`t'tus court directs either Party '() file a Petition for APPointment of the Divorce Master to re,c:>>ve.
the remaining economic issues incident to this. divorce.
BY THE COURT,
J.
ROBIN K. CREEK, : IN THE COURT OF COMMON PLEAS
OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
D,)UGLAS E. CREEK, NO. 3340 CIVIL TERM 1993
Defendant : IN DIVORCE
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PE
T—'TFOiNi FOR 1.'LE AA SOI UTF
3
COMES NOW, Plaintiff, Robin K. Creek, by and through her attorney, James J. Ka
yer,Esquire,
and petition;; the Court as follows:
1. Pc titiorter is the Plaintiff if) the above-captioned matter.
f 2. Respondent is the Defendant in C}re aboue-Coptioned matter.
i
3. On June 26 1996, the Petitioner filed with this
Court <i Petition for Bifurcation and This
Honorable Court On July 3, 1996, issued a Rule to Show C:ausfk Wily Bifurcation
t Should Not bt Granted
in this matter. A copy of this Petition and Rule are attached hereto and designated as Exhibit A.
4. On July 16, 1996, the. Sheriff of Ch ;tian County, Kentucky, served upon the Respondent
a Certified copy of the Petition for Bifurcation filed with the court on .;une 26, 1996. A copy of t_hc
Sheriff's Affidavit of Service has been attached hereto and designated as Exhibit B.
5. Neither respondent nor his counsel have responded it '.Tnely fashion to the Rule to
Show
I -�tusc' :Piled by this I-Icnorable Court c)jl July 3, 1996,
6� Petitioner and Respondent have been separated since
since that date_ 1990 and have ]i.adseparate and apart
7. Petitioner tiled an amended Complaint in Divorce on June 26, 1996,alleging the marriage was
irretrievably broken.
7`he Respondent was Nerved with Defendant`; Counter-Affidavit under Section 33
0 1(d) of the
Divorce ('erde l,y slteriff c>n srtrt}e date as Petition for Bifurcation, hrly 16, 1996 and has not c
irnr1 returned the COUnter-Affidavit. completed
9. `lle period allowed under the Pennsylvania Mules of Civil Procedure for the Res
to
cotrtplete and return tile s deem
e Defendant's Counter-Affidavit has been satisfied and he i Respondent ed to have
waived any objection to equitable distribution of the marital property by this court.
WHEREFORE, the Petitioner requests this Honorable Court to bifurcate the div
trial on all equitable distribution of marital prat rty. divorce and order
Respectfully submitted,
Jame; :a r, quire
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY �
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STATE OFPEN NA.
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ROBIN K. CREEK,
Plaintiff t>. 3s .6 ... CIVIL 1993 ? :
DOUGLAS E. CREEK, d►
Defendant
DECREE IN
D i V 0 R C E
AND NOW it is ordered and
t ^ i
decreed that ROB1N � rREVK K
py . . . Plaintiff,
4 f and .DQQU.Qi,.H . . . . ,
defendant,
•` are divorced from the bonds of matrimony. s
J�k
•
The court retains jurisdiction of the following claims which have
i
been raised of record in this action for which a final order has not yet
been entered;
Equitablel Distribution
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� r0tho»v#atry
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Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
ROBIN K. CREEK,
Plaintiff
v.
DOUGLAS E. CREEK,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: NO. 3346 CIVIL 1993
: CIVIL ACTION - LAW
Defendant : IN DIVORCE
CERTIFICATE PREREQUISITE TO SERVICE OF A
SUBPOENA PURSUANT TO RULE 4009.22
PENNSYLVANIA
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As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22,
Plaintiff certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena attached hereto
was mailed or delivered to each party at least twenty 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; and
(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: / 4 Ott V
Respect
itted,
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. 32317
Attorney for Plaintiff
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
ROBIN K. CREEK, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 3346 CIVIL 1993
DOUGLAS E. CREEK, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT
TO RULE 4009.21
Plaintiff, Robin K. Creek, intends to serve a subpoena identical to the one 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: 107/1O -7(Y
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Ciimberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
Attorney for Plaintiff
ROBIN K. CREEK, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 3346 CIVIL 1993
DOUGLAS E. CREEK, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
PURSUANT TO PENNSYLVANIA RULE 4009.22
To: Defense Finance and Accounting Service
U.S. Military Retired Pay
P.O. Box 7130
London, KY 40742
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following documents or things:
1. Any document or thing showing the current address and/or address of record for
Douglas E. Creek, whose social security number is 577-82-5461. His last known
address was 584th Maintenance Company, Fort Campbell, Kentucky 42223.
2. Any document or thing which shows the monthly pension values payable to
Douglas E. Creek as of the following dates, or, if the information is unavailable as
of that date, as of the next available date.
a. July 21, 1985
b. October 12, 1993
c. Presently
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 attend or 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.
This subpoena was issued at the request of the following person:
Name: Barbara Sumple-Sullivan, Esquire
Address: 549 Bridge Street
New Cumberland, PA 17070
Telephone: (717) 774-1445
Supreme Court ID#: 32317
Date:
BY THE COURT:
Prothonotary/Clerk, Civil Division
Seal of the Court Deputy
Official Note: This form of subpoena shall be used whenever a subpoena is issuable, including hearings in connection
with depositions and before arbitrators, masters, commissioners, etc. in compliance with Pa. R.C.P. No. 234.1. If a
subpoena for a production of documents, records or things is desired, complete paragraph.
ROBIN K. CREEK, : IN THE COURT OF COMMON PLEAS
Plaintiff
v.
DOUGLAS E. CREEK,
Defendant
X Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1993-3346
: CIVIL ACTION - LAW
: IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
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Defendant, moves the court to appoint a master with respect to the following -claims
Divorce
Annulment
Alimony
Alimony Pendente Lite
and in support of the motion states:
(1) Discovery is X is not complete as to the claim(s) for which the appointment of a master is
requested.
(2) The non-moving party _X_ has has not appeared in the action X personally
by counsel,
The statutory ground(s) for divorce are: None. This matter was bifurcated and the divorce was granted
on December 24, 1996.
(4) Delete the inapplicable paragraphs:
(a) The action is not contested.
(b) An agreement has been reached with respect to the following claims: Divorce. The parties were
divorced on December 24, 1996.
(c) The action is contested with respect to the following claims: Distribution of Property.
The action _ involves _X_ does not involve complex issues of law or fact.
The hearing is expected to take one half (1/2) day.
Additional information, if any, relevant to the motion: None.
X Distribution of Property
Support
Counsel Fees
Costs and Expenses
C
(3)
(5)
(6)
(7)
Dated: .Z?
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
ORDER APPOINTING THE MASTER
AND NOW, , 2014,
appointed Master with respect to the following claims:
, Esquire is
By the Court,
J.
ROBIN K. CREEK, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 1993-3346
DOUGLAS E. CREEK, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
CERTIFICATE OF SERVICE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and
correct copy of the Motion to Appoint a Master, in the above -captioned matter upon the following
individual, by United States first-class mail, postage prepaid, addressed as follows:
DATE: 3 — 26 It
Mr. Douglas E. Creek
242 Golden Pond Avenue
Oak Grove Kentucky, 42262
arbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court ID. 32317
Attorney for Plaintiff
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
ROBIN K. CREEK,
Plaintiff
v.
DOUGLAS E. CREEK,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 3346 CIVIL 1993
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO ENTER APPEARANCE
Please enter my appearance on behalf of Robin K. Creek in the above -captioned matter.
Upon review of the records of the Disciplinary Board of the Supreme Court of Pennsylvania it is
believed that prior counsel, James J. Kayer is no longer actively practicing law in the Commonwealth
of Pennsylvania.
a// /
Dated. /�(f
Respectfully
itted,
arbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D. 32317
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ROBIN K. CREEK, : IN THE COURT OF COMMON PLEAS
Plaintiff
v.
DOUGLAS E. CREEK,
Defendant
X Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1993-3346
: CIVIL ACTION - LAW
: IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
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Defendant, moves the court to appoint a master with respect to the following -claims:
Divorce
Annulment
Alimony
Alimony Pendente Lite
and in support of the motion states:
(1) Discovery is X is not complete as to the claim(s) for which the appointment of a master is
requested.
(2) The non-moving party X has _ has not appeared in the action X personally
by counsel,
The statutory ground(s) for divorce are: None. This matter was bifurcated and the divorce was granted
on December 24, 1996.
(4) Delete the inapplicable paragraphs:
(a) The action is not contested.
(b) An agreement has been reached with respect to the following claims: Divorce. The parties were
divorced on December 24, 1996.
(c) The action is contested with respect to the following claims: Distribution of Property.
The action involves _X_ does not involve complex issues of law or fact.
The hearing is expected to take one half (1/2) day.
Additional information, if any, relevant to the motion: None.
X Distribution of Property
Support
Counsel Fees
Costs and Expenses
(3)
(5)
(6)
(7)
Dated: Z'/
Apy
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
ORDER APPOINTING THE MASTER ?
201,40- e Q/v_T E ��
AND NOW,squi�e��
appointed Master wit espect t e following claims: (6.0
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