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HomeMy WebLinkAbout05-3726HAROLD E. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17049 (717) 2434090 ATTORNEY FOR PLAINTIFF SHARON A. LACY , : IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA ?. : CIVIL ACTION - LAW NO. 2005 -3VLCIVIL TERM JOE P. LACY, Dsfandant : 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 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-243-3166 SHARON A. LACY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2005 -Z,&4-CIVIL TERM JOE P. LACY, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 330i(e) OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is SHARON A. LACY, an adult individual residing at 601 Bloserville Road, Newville, Cumberland County, Pennsylvania 17013. 2. The defendant is JOE P. LACY, an adult individual presently residing at 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on September 13, 2002 in Carlisle, Cumberland County, Pennsylvania, 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. July 22, 2005 SHARON A. LACY, Plaintiff/ HAROLD S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 SHARON A. LACY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2005 - CIVIL TERM JOE P. LACY, , Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and 1 participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. July 22, 2005 ??Lx / /? , ? HARON A. LACY, Plaintiff J J ? T -C N n SHARON A. LACY , : IN THE COURT OF COMMON PLEAS OF Plalntlff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW :NO. 2005 -,CIVIL TERM JOE P. LACY, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(1) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on July 26, 2005, by certified mail addressed to him at 1101 Claremont Road, Carlisle, Pennsylvania 17013, certified mail No. 7004 1350 0003 7287 2865. 3. A copy of the sender's and return receipts are attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. IV I2cW Z 3, ZoG) Harold S. Irwin, III Attorney for plaintiff 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court ID No. 29920 u, ru N L P F ru U r- r? Postage 7 O COMW Fee C3 O Retum Reciept Fee (Endorsement Required) C3 Restricted Delivery Fee (Endorsement Required) M r=1 O C3 r1- ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can retum the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. ------------- 1. Article Addressed to: J G P. LaCq C mberIQret Cs tn4-( PYtCai Hot 0-10(emoK4 -Pot Ca- rj1SJe PA I )af3 r ere A. R ved e s ?t Cfearfy) B. Date of C. Signature X Pr ? Agent ? Addre D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. ice Type Certified Mail ? Express Mail P_FfbgWered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Ytm 2. Article Number (Transfer from service fader) 9992 t'_ Q 2 Z E0010 O S E T h 0 0 2. PS Form 3$11, March 2001 Domestic Return Receipt 102595-01-M-1424 EXHIBIT ^p•• rr- ? ? e C7 Rt ? N " < SHARON A. LACY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2005 - *W CIVIL TERM JOE P. LACY, 31;je Defendant : IN DIVORCE PETITION FOR RULE TO SHOW CAUSE NOW comes Harold S. Irwin, III, Esquire, attorney for plaintiff, and presents this petition for a rule to show cause, representing as follows: 1. Petitioner is HAROLD S. IRWIN, III, attorney for plaintiff, with offices at 64 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondents are SHARON A. LACY, an adult individual residing at 601 Bloserville Road, Newville, Cumberland County, Pennsylvania 17241, and JOE P. LACY, an adult individual currently residing at Camp Hill State Correctional Institution, P. O. Box 200, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Petitioner has represented the plaintiff in this matter since July, 2005. 4. The plaintiff has filed a complaint in divorce and an amended complaint. Defendant has not formally responded to either complaint. 5. The plaintiff has requested that petitioner withdraw from her representation. 6. Petitioner believes and therefor avers that neither party will be prejudiced by petitioner's withdraw, should this Court grant petitioner's request. 7. No judge has been involved in this case to date. WHEREFORE, petitioner requests your Honorable Court to enter a rule upon the respondents to show cause why petitioner should not be permitted to withdraw from this case as counsel for plaintiff. March 24, 2008 tl-? HAROLD S. IRWIN, III Petitioner 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court ID No. 29920 VERIFICATION The foregoing petition is true and correct to the best of my knowledge, information and belief. understand that false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4094, relating to unsworn falsification to authorities. March 24, 2008 HAROLD S. IRWIN, I{ Petitioner ?? ? { '"L"{ -.? _ ..- .? u ?.? ?^. r9 + ' :r`j 1 --i .b t i?•-?: i .. J W26 HAROLD S. IRWIN, 111, ESQUIRE SUPREME COURT ID NO. 29920 64 SOUTH PITT STREET CARLISLE, PA 17018 717-2434MM ATTORNEY FOR DEFENDANT SHARON A. LACY, : IN THE COURT OF COMMON PLEAS OF Plalintlff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2005 -401111111?,CIIVIL TERM JOE P. LACY, '3-79t f Defendant : IN DIVORCE ORDER OF COURT th NOW, this f day of May , 2008, on petition of Harold S. Irwin, III, Esquire, a rule is hereby issued upon the parties, SHARON A. LACY and JOE P. LACY, to show cause why petitioner should not be permitted to withdraw as counsel for plaintiff. Rule returnable It days after the date of this order. Service to be by regular mail upon the parties. By the Court, i il?l VINYAIANN?d Cl\ c i7•?I WV J1 AN gooL x SHARON A. LACY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2005 --*GrrCIVIL TERM JOE P. LACY, 3-7ab Defendant : IN DIVORCE PETITION TO MAKE RULE ABSOLUTE NOW comes Harold S. Irwin, III, Esquire, attorney for plaintiff, and presents this petition ro make the rule absolute, representing as follows: Petitioner is Harold S. Irwin, III, attorney for plaintiff, with offices at 64 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondents are Sharon A. Lacy and Joe P. Lacy, the parties to this divorce action. 3. Petitioner has represented plaintiff in this matter since its inception. 4. On or about May 15, 2008, on petition of Harold S. Irwin, III, Esquire, Judge M. L. Ebert, Jr., issued a rule upon the parties to show cause why petitioner should not be permitted to withdraw as counsel for plaintiff, returnable twenty days after the date of the Order and service to be by certified mail upon the parties. 5. The parties were served on June 2, 2008 and June 12, 2008, respectively, as shown on the certified mail receipts made a part hereof and attached hereto as Exhibit "A". 6. To date, neither party has filed a response to the Rule. WHEREFORE, petitioner requests your Honorable Court to make the rule entered upon the parties to show cause why petitioner should not be permitted to withdraw from this case absolute. November 5, 2008 ?J HAROLD S. IRWIN, II, VERIFICATION The foregoing petition is true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4094, relating to unsworn falsification to authorities. November 5, 2008 HAROLD S. IRWIN, III, 16 ¦ Complete Itatxp;1 2WWA,,A0G compleil3 Item 4 if Restrict?Cf DelQy, 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 mallpiese, or on the front if space permits. 1. Article Addressed to: JQE °LACY INMATE NO HL-3221 CAMP HILL CORRECTIONAL INE PO X 200 04AM, HILL PA 17011 A. ? Agent 0 Addre B. R Name C. Of D*.Wy D. is delivery address different from Mom 1 if YES, enter delivery address below: . , ® (Domestic Mail Only; No Insurance 1 u7 W...W.,........ n Express Mail ° ? Retum Receipt r 13 ru 1 . ?? ff Postage $ Insured Mail E3 C.O.D. Q Y ?erti tj ed Fee 4. Restricted Delivery? (Extra Fee) M ° Return Receipt Fee C3 (Endorsement Required) 2. Article Number 7007 0710 0003 2206 5925- ° (fansler from service lab (EndoIncted rse ero®RequireFee d) PS Form 3811, February 2004 Domestic Retum Receipt r-:I - r` Total Postage & Fees ° U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only, No Insurance Coverage Provided) For delivery information visit our website at www.usps. -0 1 ° ru ru Postage s•7 qr ??,pp $ l;9rlifte9 Fee fn ° ° Return Receipt Fee (Endorsement Regwred) 0 Restricted Delivery Fee O (Endorsement Required) r? Postm4rk Here f1- se t To ° ..__: -- ----- - ---- O Street, t. No.; rl- or PO Box No. -------------------------- - e City fate, ZIP+4 C i7 SeL Reveise for Instruction= 21 ¦ Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse Postm so that we can return the card to you. Hen ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: r`- Total Postage & Fees ° SHARON A LACY sent To 601 BLOSERVILLE RD C3 sheer, ------ ., - . "" NEWVILLE PA 1 7 2 41 or PO Box No. 67 O ?. ------------ ---------------- 1---'--- City, S te, ZIP+4 ?l PS For in 3800 verse f9 an =fC - oceived by d N tL_ dNN y address differ ite A YES, enter delivery ad o 3. ? Express Mail egistered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number 7007 0710 0003 2206 5895 (Transfer from service laW PS Form 3811, February 2004 Domestic Return Rooeipt 102595-02-M-1540 L__ EXHIBIT "A" = C r J7 ? S` f5 NOV 0 6 20086 5 HAROLD S. IRWIN, 111, ESQ. SUPREME COURT ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR DEFENDANT SHARON A. LACY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2005 - 40" CIVIL TERM JOE P. LACY, ; 374 Defendant : IN DIVORCE ORDER OF COURT t? NOW, this day of November, 2008, on petition of Harold S. Irwin, 111, Esquire, the rule issued upon the parties to show cause why he should not be permittd to withdraw as counsel for plaintiff is hereby made absolute. By the Court, r? 0 C?I } HAROLD S. IRWIN, 111, ESQUIRE SUPREME COURT ID NO. 29920 64 SOUTH PITT STREET CARLISLE, PA 17013 717-243-6090 ATTORNEY FOR PLAINTIFF SHARON A. LACY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2005 --10r CIVIL TERM JOE P. LACY, 37aty Defendant : IN DIVORCE PRAECIPE FOR WITHDRAWAL APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance for the plaintiff in this matter, pursuant to the attached Order of Court, dated November 6, 2008. November 13, 2008 HAROLD S. IR"N, III, ESQUIRE Supreme Court No. 20 64 South Pitt Street Carlisle, PA 17013 717-243-6090 •' NOV 0 ,6 2008 6n HAROLD S. IRWIN, 111, ESQ. SUPREME COURT ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR DEFENDANT SHARON A. LACY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. ZOOS -•4027-CIVIL TERM JOE P. LACY, 37d-1( Defendant : IN DIVORCE - ORDER OF COURT NOW, this 6 Ic day of November, 2008, on petition of Harold S. Irwin, 111, Esquire, the rule issued upon the parties to show cause why he should not be permittd to withdraw as counsel for plaintiff is hereby made absolute. By the Court, ?J. Testimony whereof, ) hero unto get my bane a the M1 of said Court at Coil, PL iA, ?..?y dd.. .??= Pletherlow? y s s SHARON A. LACY, : IN THE COURT OF COMMON PLEAS OF PIalntW : CUMBERLAND COUNTY, PENNSYLVA"A G ° Q v. : CIVIL ACTION - LAW ?' n y : NO. 2005 - 492'YCIVIL TERM ? JOE P. LACY, Defendant : IN DIVORCE y ' PETITION TO MAKE RULE ABSOLUTE , NOW comes Harold S. Irwin, III, Esquire, attorney for plaintiff, and presents this petition ro make the rule absolute, representing as follows: Petitioner is Harold S. Irwin, III, attorney for plaintiff, with offices at 64 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondents are Sharon A. Lacy and Joe P. Lacy, the parties to this divorce action. 3. Petitioner has represented plaintiff in this matter since its inception. 4. On or about May 15, 2008, on petition of Harold S. Irwin, III, Esquire, Judge M. L. Ebert, Jr., issued a rule upon the parties to show cause why petitioner should not be permitted to withdraw as counsel for plaintiff, returnable twenty days after the date of the Order and service to be by certified mail upon the parties. 5. The parties were served on June 2, 2008 and June 12, 2008, respectively, as shown on the certified mail receipts made a part hereof and attached hereto as Exhibit "A". 6. To date, neither party has filed a response to the Rule. WHEREFORE, petitioner requests your Honorable Court to make the rule entered upon the parties to show cause why petitioner should not be permitted to withdraw from this case absolute. November 5, 2008 HAROLD S. IRWIN, III, Petitioner r] Complete ? t?mplei'e`? Item 4 If Delhiery.is destfeL; . ¦ Print your name and address on tiro reverse so that we can retum the card to you. ¦ Attach this card to the back of the malplece, or on the-front H space permits. 1,. Article Addressed to. V1 J E ZACY INMATE NO HL-3221 A Sign?t}?re X r °? 0 Agent 0 Addressee B. R Name C. t?at of Delivery D. Is delivery address different from Item 1 It YES. enter delivery address below: .? 01 C M HILL CORRECTIONAL INS ti (Domestic Only: - Coverage Provided) P rX 20D Q' rrr MHILL PA 17011 3. OFFICIAL US Express Mall 0 Retum Receipt rrU 4 l1 Poetap $ ? Insured Mail ? C.O.D. Y F. 1 4. Restricted Delivery? #D ft Fee) rrl _ r ?. Article Number C3 (Endorsement Requtired) PHere:.k Fee 7007 0712 01203 2206 5925 M ' {rransfer from Ser" rr+ +- Restricted oeNvery Fee i P5 forth 3811, February 2004 Domestic Return Receipt a (ErMorsement Required) r Total Postage & Fees $ ?. r3 to ...--- ------------ -- -- ----------- U.S. CERTIFIED MAIL RECEIPT _Pk7 C+R W L ranc e Cov erage Prov idec webs ite at w ww.us ps.c S E , ?4(?? o $ ??7+ Alfdf! Fee Return Reoetpt Fee (Endorsement Required) Restricted DelNery Fee (Erxrorsement Required) ':10 Complete Items 1, 2, and 3. Also complete i item 4 N Restricted Delivery Is desired. j ¦ Print your name and address on the reverse Poear so that we can return the card to you. Heh: ¦ Attach this card to the hack of the mailpiece, or on the front If space permits. 1. Article Addressed to: SHARON A LACY 601 BLOSERVILLE RD NEWVILLE PA 17241 by tf YES, enter delivery &0 3. " Type WW - O Express Mali 10 Registered ? Return Receipt for Merchandise 0 Insured mail E3 C.O.D. 4. Restricted Delivery' 05ft Fee) ? Yes 2. Article Number; 7007 0710 0003 2206 5895 (rransferfrom sery/W kw PS Form 3811, February 2004 Domestic Return Receipt 1025e6-024A-164 EXHIBIT ••A" Total Postage & Fees , $ S-.'2,>, t"3 Y -T J 1w ? ?f SHARON A. LACY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V.. : NO. 2005 - 3726 Civil Term JOE P. LACY, : CIVIL ACTION - DIVORCE Defendant NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION. The parties to this action separated on March 15, 2007 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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: Sharon A. Lacy, Plaintiff RL D-OffiCE 2009 APR 21 P 1. 13 SHARON A. LACY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 20C15 - 3726 Civil Term JOE P. LACY, : CIVIL ACTION - DIVORCE Defendant NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: Joe P. Lacy, Defendant Date: April 27, 2009 SCI Chester 500 East 41h Street Chester, Pa. 19013 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, in twenty days, after May 17, 2009, the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 16 SHARON A. LACY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 3726 Civil Term JOE P. LACY, : CIVIL ACTION - DIVORCE Defendant COUNTER-AFFIDAVIT UNDER SECTION 3301(d) of the DIVORCE CODE 1. Check either (a) or (b): _(a) I do not oppose the entry of a divorce decree. X_(b) I oppose the entry of a divorce decree because: (Check (i),(ii), or both:) _(i) The parties to this action have not lived separate and apart for a period of at least two years. X(ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, and expenses if I do not claim them before a divorce is granted. $(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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: - 6 0 J y, efendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. C3 c ? ice, 1^ 00 C-n SHARON A. LACY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 3726 Civil Term JOE P. LACY, : CIVIL ACTION - DIVORCE Defendant COUNTER-AFFIDAVIT UNDER SECTION 3301(d) of the DIVORCE CODE 1. Check either (a) or (b): _(a) I do not oppose the entry of a divorce decree. _)L(b) I oppose the entry of a divorce decree because: (Check (i),(ii), or both:) _(i) The parties to this action have not lived separate and apart for a period of at least two years. ) (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, and expenses if I do not claim them before a divorce is granted. X_(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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: SY o y A?__ J y, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. FILE-. FTs'F 2009 iUli --Z A i ! f y C, SHARON A. LACY, JOE P. LACY, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 3726 Civil Term : CIVIL ACTION - DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 SHARON A. LACY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 3726 Civil Term JOE P. LACY, : CIVIL ACTION - DIVORCE Defendant AMENDED COMPLAINT IN DIVORCE UNDER SECTION 3301(C) AND 3301(Q) OF THE DIVORCE CODE AND NOW COMES, Plaintiff, Sharon A. Lacy, by and through her attorney, Jane Adams, Esquire, and files this amended complaint against the Defendant, as follows: 1. Plaintiff is Sharon A. Lacy, an adult individual residing at 601 Bloserville Road, Newville, Cumberland County, Pennsylvania, 17013. 2. Defendant is Joe P. Lacy, an adult individual residing at 500 East 4th Street Chester, Pa. 19013 3. Plaintiff and Defendant are sui juris and have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. The parties were married on September 13, 2002 in Carlisle, Cumberland County. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant are in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jursidiction. 8. The Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. COUNTI Request for Divorce Due to Irretrievable Breakdown Under 3301(c) of the Divorce Code. 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. The marriage of the parties is irretrievably broken. 11. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, as the marriage is irretrievably broken, Plaintiff requests the court to enter a decree in divorce under section 3301(c) of the Divorce Code upon filing of Affidavits of Consent. COUNT II Request for Divorce Due to Irretrievable Breakdown and two year separation Under 3301(d) of the Divorce Code. 12. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 13. A period of two years has elapsed since the date of the parties' date of separation, and Plaintiff has filed her affidavit under 3301(d) of the divorce code. 14. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, Plaintiff requests the court to enter a decree in divorce under section 3301(d) of the Divorce Code since the marriage is irretrievably broken and a two year period of separation has elapsed. I verify that the statements made in this Amended Complaint 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. oa,eto ? (v9 J , &)WX- L?- Q cte?' ,,5haron A. Lacy, Plaintiff Respectfully submitted, Roams, tsquire . No. 79465 1 West South St. arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF FiLD"', Rid A? ., ?1l5. ,f 1. , SHARON A. LACY, Plaintiff V. JOE P. LACY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05 - 3726 CIVIL ACTION - LAW Divorce PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Joe P. Lacy, the Defendant, in the above captioned matter. 2009 KryMac tyr Certified Legal Intern Megan esmeyer, Esq. Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 OF THE 71 2 0 0 9 UG I I Pit 2: 1 ; j SHARON A. LACY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 3726 Civil Term JOE P. LACY, : CIVIL ACTION - DIVORCE Defendant ACCEPTANCE OF SERVICE I, Krystal Maclntyre, Certified Legal Intern with the Family Law Clinic, represent Joe P. Lacy, in the above-captioned matter; I hereby accepted service of the Notice to Defend and Amended Complaint on the date listed below, on behalf of Defendant, which was filed by Plaintiffs Attorney under the above-captioned number and I hereby affirm I was authorized by Defendant to do so. Date: Al 1E Ing Kryal M Inty Certified gal Intern 45 N. Pitt St. Carlisle, P .,17013 (717) 243- '68 OF MVATAW AUGI 1 4 PSI f: 21 AMC" Y SHARON A. LACY, Plaintiff/Respondent V. JOE P. LACY, Defendant/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW DIVORCE : NO. 2005-3726 PETITION FOR EQUITABLE DISTRIBUTION AND NOW comes Mr. Joe Lacy, the Defendant/Petitioner in the above-captioned divorce action, by and through his attorneys, the Family Law Clinic, and sets forth the following Petition for Equitable Distribution, pursuant to Pa.R.C.P. No. 1920.15(b): 1. On July 22, 2005, Plaintiff/Respondent filed a Complaint in Divorce under Section 3301(c) of the Divorce Code. 2. On August 10, 2009, Plaintiff/Respondent filed an Amended Complaint in Divorce under Section 3301(c) and 3301(d) of the Divorce Code. 3. Petitioner and Respondent were married on September 13, 2002 in Carlisle, Cumberland County, Pennsylvania. 4. During the course of the marriage, the parties acquired marital assets and debts subject to equitable distribution under Section 3302 of the Divorce Code, including, but not limited to the following: a) Plaintiff's pension, 401(k) account, retirement accounts, bank accounts; b) Various items of personal property. WHEREFORE, Petitioner requests that this court equitably divide the marital property and debts between the parties and grant such other relief as the Court deems just. Respectfully submitted, Date c 1Pf . 4'j -2oa Kryst 1 Mac ntyi Certified Legal Intern ROB INS THOMA M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER KATE CRAMER-LAWRENCE Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 Telephone: (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this Petition for Equitable Distribution are true and correct to the best of my personal knowledge, information, and belief. 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: &W-L?aacy, Petitioner SHARON A. LACY, Plaintiff V. JOE P. LACY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY : NO. 05-3726 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Joe P. Lacy, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing. free legal service to the party. Date Respectfully submitted, Kry al Ma ntyr Certified Legal Intern L ROBE S THOMAS . PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 4, c - , .,F ? . , ; ?, f SANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadamsQgmail.com SHARON A. LACY, V. JOE P. LACY, i=fL~~i.; ~_. ~~~ Yf-"c ~"' r w~Y r~~ \1 `,lam Y~1,{ lr~F :~;*~>11''a IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005 - 3726 Civil Term Defendant CIVIL ACTION -DIVORCE AFFIDAVIT OF SERVICE I, Jane Adams, Esquire, do hereby certify that on May 4. 2009, served a true and correct copy of the AFFIDAVIT OF SEPARATION AND O~UNTER-AFFIDAVIT in the above-captioned. matter upon the following individuail{s) by certified mail, return receipt requested, addressed as fellows; Joe Lacy, Defendant SCI Chester 500 East 4th St. Chester, Pa. 19013 oa~e:71~S/(b ^ Complete items i , 2. and 3. Also complete ~ kern 4 H Restricted Delivery is desired. ~ At~t ^ Print your~ame and address on the reverse ,, ^ Addressee so that we can return the card to you. ~ ° B. by (Printed Nerve) c. Date of Delivery ^ Attach this card to the hack of the maUpleoe,. a on the front H space permits. D. is delivery address dilferern irnrn ihsm t? ^ Yes . Article Addressed to: ff Yea enter delivery address aebvw ~ D Plo ~l..o.c~ Sc~~ C~ ~C~ Co~'1- U`°'' s~ s. serrrice,ype t Oartlfled Mall ^ E~resa Mail D RapMared D Return Receipt for Mercharrdlae ^ lnau~ad Mew ~ c.o.D. 4. RaMririad DaNwry? IExtrs Fee! ^ Yes 2. ArticWtJumber .7007 1490 ^0~3 0141 8052 (Tiansli~r f-nm service label) P5 Form 3811, Fetxuary 2004 Domestic Return Receipt toxeYB.a~M-tell ane Adams, Esquire .D. No. 79465 17 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF .~ ~~I f '_- r, iANE ADAMS . ~ ~- ATTORNEY AT LAW ~~ ~ ~ ~`~' = ~ ~ ~ ~ #~~~ Attorney I.D. No. 79465 ; r ?i~~`t 17 W. South St. Carlisle, Pa. 17013 Cl:`i,l-~ _ i-~' `` ~ ~ ~,,` :`r• ~'lir'. (717)245-8508 esgadams®gmail.com SHARON A. LACY, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 3726 Civil Term JOE P. LACY, :CIVIL ACTION -DIVORCE Defendant AFFIDAVIT OF SERVICE I, Jane Adams, Esquire, do hereby certify that on June 24. 2010, I served a true and correct copy of the NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE AND PRAECIPE in above-captioned matter upon the following individual(s) by certified mail, return receipt requested, addressed as follows: Joe P. Lacy, Defendant c/o Daniel Puskar, Certified Legai Intern Family Law Clinic 45 N. Pitt St. Carlisle, Pa. 17013 A copy of the return receipt and the documents served are attached. Respectfully Submitted: Date: ~ ~,.lj ~~ ~ne Adams, Esquire D. No. 79465 17 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~~ ~+ UNfTFDSTATES PQSTAtSERVKE. Date: 06/24/2010 Jane Adams: The following is in response to your 06/23/2010 request for delivery information on your Certified Mail(TM) item number 7008 2810 0002 2909 8868. The delivery record shows that this item was delivered on 06/24/2010 at 09:29 AM in CARLISLE, PA 17013. The scanned image of the recipient information is provided below. .+..~..~.~ v.~.wa Signature of Recipient: ~ :~~ ~ «,~ ~, ~'° C~'~~ Address of Recipient: '~- r ~C- r 1 ~~ ~ `7 J /v Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service y Jane Adams ATTORNEY AT LAW 17 WEST SOUTH STREET CARLISLE, PA. 17013 (717) 245-8508 voice (717) 241-2456 fax esgadams@gmail.com ?~08 2810 002 2909 8868 VIA CERTIFIED MAIL May 25, 2010 Daniel Puskar, Certified Legal Intern Family Law Clinic 45 N. Pitt St. Carlisle, Pa. 17013 Re: Lacy v. Lacy Dear Daniel: Enclosed please find a Notice of Intent to Request Entry of Divorce Decree and Praecipe. Thank you for your attention to this matter. Sincerely, squire cc: Shy •. SHARON A. LACY, JOE P. LACY, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 3726 Civil Term CIVIL ACTION -DIVORCE Defendant NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Joe P. Lacy, Defendant c/o Daniel Puskar, Certified Legal intern Family Law Clinic 45 N. Pitt St. Carlisle, Pa. 17013 Plaintiff, Sharon A. Lacy, intends to file with the Court the Attached Praecipe to Transmit Record on or after Ju{y 13, 2010, requesting that a final decree in Divorce be entered. o.~e: ~~aa /~o t Respectfully sub Ja Adams,-Esqu ri e I . No. 79465 W. South St. arlisle, Pa. 17013 ATTORNEY FOR PLAINTIFF ~, SHARON A. LACY, V. JOE P. LACY, TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA Defendant NO. 2005 - 3726 Civii Term CIVIL ACTION -DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 3301 d of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered b certified mail on Jul 26, 2005: amended complaint served on or about August 12 2009 acceptance of service signed by legal intern assisting defendant and was filed August 14 2009 3. Date of execution of the affidavit required by §3301 (d) of the Divorce Code: By Plaintiff: March 25. 2009. Date of filing and service of the plaintiffs affidavit of separation required by §3301 (d) of the Divorce Code on respondent: Filed: April 21, 2009. Served on Defendant: On or about Mav 24 2009 via certified mail Affidavit of Service filed: Contemporaneously with this agreement 4. Related claims pending: None; all have been resolved by a written marriage settlement agreement. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which was filed of record with the Prothonotary, along with an Affidavit of Service: Sent to Defendant's representation at Family Law Clinic via certified mail. Respectfully Submitted: Date: Jane Adams, Esquire I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ~A ~ ~`~~~ ,~- c ~ " "'d~Y 'C*- ". , 21SIU ~4~ 1 ~ ~~1~ ~' 1 iANE ADAMS , , , ,v,,E~ C PJ , ATTORNEY AT LAW r'~- Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadamsCQ3gmail.com SHARON A. LACY, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 3726 Civil Term JOE P. LACY, :CIVIL ACTION -DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff: March 25, 2009. TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: Code. 1. Ground for divorce: irretrievable breakdown under 3301 d of the Divorce 2. Date and manner of the service of the Complaint: Delivered by certified mail. on Julv 26, 2005, via certified mail. Acceptance of Service filed dated March 23 2007 Amended complaint was served and accepted on August 13 2009 acceptance of service filed August 14, 2009. Date of filing and service of the plaintiffs affidavit of separation required by §3301(d) of the Divorce Code on respondent: Filed: April 21, 2009. Served on Defendant: On or about May 4. 2009. Via certified mail. Acceptance confirmed: Defendant signed and filed counter-affidavit May 6, 2009. Affidavit of Service filed: An affidavit regarding_service of the Affidavit of separation is being filed contemporaneously with this Praecipe 4. Related claims pending: None: after filing of the Affidavit of Separation and counter-affidavit. Defendant was represented by the Family Law Clinic The parties entered into a comprehensive marriage settlement agreement which addressed and resolved all outstanding claims Pursuant to stipulation the agreement was not filed of record. There are no outstanding claims other than divorce. Plaintiff is requesting the divorce proceed under section 3301 (d) as the parties have been separated for more than two years the Notice of Intent to Request Entry of Final Divorce Decree was served more than twenty days from the date of this filing_ 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which was filed of record with the Prothonotary, along with an Affidavit of Service: Plaintiff s Notice of Intention to file Praecipe to Transmit record was served on the Family Law Clinic on June 24 2010 via certified mail return recut requested; affidavit of service is being_filed contemporaneously with this Praecipe oa~~~s~~ Respectfully Submitted: ne Adams, Esquire .D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff SHARON A. LACY, V. JOE P. LACY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2005 - 3726 Civil Term NO. DIVORCE DECREE ~-' 3.'39~.~, AND NOW, ~s ~~~ , it is ordered and decreed that SHARON A. LACY, ,plaintiff, and JOE P. LACY, ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None; all outstanding claims have been resolved by a marriage settlement agreement; said settlement agreement, signed by the parties on April 6, 2010, shall be incorporated and not merged into this Decree. B Court, Attest: J. ~- Prothonot ry '~`~ U `7 - f ~' - l O /C~o-ti c.sz. c~c~.~ `ec~ ~'° `~r~.nrti~ ~ (~,~ C'it<<n, c, SHARON A. LACY, JOE P. LACY, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005 - 3726 Civil Term V. CIVIL ACTION -DIVORCE Defendant To the Prothonotary: NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter: prior to the entry of a Final Decree in divorce. OR ~ after the entry of a Final Decree in Divorce A, n°;°a c- o ~-' ® _~ c. , -,-, -- ~ ~ _ ~ ----, - ~ ~.: - c: _ .: hereby elects to resume the prior surname of ANDERSON avowing her intention pursuant to the provisions of 54 P.S. §704. Date: ~~, Z~ ~a , haron A. Lacy Prior Name haron A. Anderson Signature of Name being resumed. COMMONWEALTH OF PEDINSYLVANIA COUNTY OF CUMBERLAND ) On this, the G~day of 2010 before me, the undersigned officer, personally appeared SHARON A. C ARON A. ANDERSON personally known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto se han and official se NOTARIAL SEAL JANE ADAMS ry Public Notey Public CARLISLE SORO., CUMBcRLAND COUNTY y commission expires: My Commlasion Expires Sip 6, 2012 cr%~~y~ 3 ~7 ~~