The URL can be used to link to this page

Home My WebLink About01-4337 4'/ az ~ ~u, ~~;:v 7J?rp -- . ( [0- hi 'L [iJ' hI 1. IRENE SHOEMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01 - 4337 CIVIL JESSE SHOEMAKER, Defendant IN DIVORCE ORDER OF COURT 2003, the F economic claim raised in the proceedings on behalf AND NOW, this -3AcL day of of the Plaintiff in the complaint having been withdrawn by praecipe filed by the Plaintiff on May 22, 2003, and there appearing to be no issues with respect to grounds for divorce, the appointment of the Master is vacated. BY THE COURT, Geo cc: Family Law Clinic Attorney for Plaintiff Jesse Shoemaker Defendant ~ ~ /YU~ ~.o-:a -03 Ct. . ~ol:b ~. 7llJv'>\ C(.o Vit~Vi\l)'':;~JNjd II"rn~"- .. '-'.....,,...,. ..... 1\1..1'; ;:.,I.} ~"-..".."i",f t....J (}! :l, l: f. . , ~ ~ IRENE SHOEMAKER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001-4337 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: a. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. b. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Jesse Shoemaker, July 19,2001. c. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff: June 13, 2002, and by the Defendant: June 2, 2003. d. Related claims pending: None ". e. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: June 16,2003. Date Defendant's Waiver of Notice was filed with the Prothonotary: June 5, 2003. Respectfully submitted, Date: 0/2-6/03 ~/~ Michael Parker Certified Legal Intern ~. ~,W~ > OBE~E. > INS THOMAS M. PLACE Supervising Attorney LUCY JOHNSTON- WALSH Staff Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 .. IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW :IN DIVORCE JESSE SHOEMAKER, Defendant :NO.2001-4337 CIVIL TERM CERTIFICATE OF SERVICE I, Michael Parker, hereby certify that I served a Praecipe to Transmit the Record on Jesse Shoemaker on ~ /:<" / 03 , by first class United States mail, at the following address: Jesse Shoemaker 127 Oak Hill Road Carlisle, P A 17013 ~/~ Michael Parker Certified Legal Intern Date: ro / 2-.~ 103 F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 71 03 (717) 243-2968 Fax: (717) 243-3639 o c:: <"' ""'01;'- rn., -y ">)' Zl 9';. ~(~' '"I> .- Z"~' ~c c Z ~ ~ ";:-,::1 _......) {'7', ',~) -~~~ ~-: :,:;~:-~ .l'~ ~ u:; ::.n (.,.) - IRENE SHOEMAKER, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE . ()1-'I33, : NO. 2001-~IVIL TERM JESSE SHOEMAKER, 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. 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, 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 YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing, IRENE SHOEMAKER, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTIQN - LAW : IN DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001- CIVIL TERM DIVORCE COMPLAINT WITII EQUITABLE DISTRIBUTION COUNT The plaintiff, Irene Shoemaker, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: COUNT I DIVORCE UNDER 23 Pa.C.S. SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Irene Shoemaker, who currently resides in Cumberland County, since February 13, 2001. 2. Defendant is Jesse Shoemaker, who currently resides at 127 Oak Hill Road, Carlisle, Pennsylvania, 17013, since August 1998. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4, Plaintiff and defendant were married on June 26, 1993 in Newville, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since on or about February 13, 2001. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, plaintiff requests the court to enter a decree in divorce dissolving the marnage. COUNT II EQUITABLE DISTRIBUTION 9. Plaintiff repeats and realleges paragraphs one through eight. 10. Plaintiff and Defendant have acquired marital assets and debts subject to equitable distribution under the Divorce Code, including, but not limited to the following: a. Marital trailer (purchased through a rent-to-own agent), b. Husband's pension and/or retirement plans, c. Vehicles, d. Household appliances, e. Power tools, f. Various personal belongings, and g. Plaintiff's medical bills. WHEREFORE, plaintiff requests the court to enter a decree dividing the property equitably between the parties and such other relief as the court deems just. Da~ I~WI Ld/J-- ~<- !~J T S M. PLACE ROBERT E. RAINS Supervising Attorney TERI L. HENNING Staff Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities. Date: ~\}vrm d9 I qGO \ ~1~ .ll\OSJfilG- ~(Qr) Irene Shoemaker ~ J 0' ~ l--I 1 ~. 0 -K ~~ ~ 1 ~ ~ ~ ~... ('> f.'-" c o ',::- q -~ vJ , , ..t:: vJ '""" :s G IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE JESSE SHOEMAKER, Defendant ~ NO. 2001- i~CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Irene Shoemaker, Plaintiff, to proceed in forma pauperis, I, Michelle L. Anderson, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party, Date: July 17, 2001 .. !i!itttfL(i!f2{dL/idI1~ ,J tiichelle L. And on Certified Legal Intern '" . '"' / ~'- 1"1 RO ERT E, RAIN . THOMAS M, PLACE TERI L. HENNING Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 o ~ ~ '" - C>[ ~~'t \,' ... ;0 I) ,.J vJ ~ "'" ~ .... "" '(, ." .... ( , t . ~ IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE JESSE SHOEMAKER, Defendant : NO. 01-4337 CIVIL TERM PROOF OF SERVICE Understanding that the making of any false statement would subject her to the penalties of 18 Pa, c.s. 94904 (relating to unsworn falsification to authorities), the undersigned verifies that Michelle L. Anderson mailed a true copy of the Divorce Complaint with Custody count on the Defendant by placing the same in the U.S, Mail, certified no. 709934000018 49969480, restricted delivery, return receipt requested, postage prepaid, on the 17th day of July, 2001 addressed as follows: J esse Shoemaker 127 Oak Hill Road Carlisle, P A 17013 Sender's receipt no. 7099 3400 0018 4996 9480 is attached hereto and incorporated by reference. On or about the 19th day of July, 2001, green return receipt no. 70993400001849969480 was delivered to the Family Law Clinic, bearing the signature Jesse B. Shoemaker and showing a date of service of July 18, 2001. The return receipt is attached hereto and incorporated by reference. ~ 25. 2DD I Date Michelle L. Anderson Certified Legal Intern F AMIL Y LA W CLINIC 45 N, Pitt St. Carlisle, PA 17013 717-243-2968 ~ . o ..- 0. ). ~ of N .]'I ,.-0 ~ ('J ~ . 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 return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits, 1. ArtIcle Addressed to: ~j~~e 0hxwoU,r I~ 1 (tdL H-n Il?COd 'wr/W( fA- {lol3 3, Service Type )r:l Certified Mail o Registered o Insured Mail o Express Mail /J r ," ... ~eturn Receipt for JIriJf1:e . o C.O.D. i 2. Article Number (Copy from service label) 10QQ 3%0 0016 IJ-CAb 4. Restricted Delivery? (Extra Fee) PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789 UNITED STATES POSTAL SERVICE RECEIVED 1 9 2001 First-Class Mail Postage & Fees Paid USPS Permit No, G-10 · Sender: Please print your name, address, and ZIP+4 in this box · \\;ticnefl( Arrferccn . qamil~ LClw C\iV1\L- U0 N O(fh '11-H dra-r CityJ($U (?A f7013 t}', ~ \, a d 'required. . For an additional fee, delivery may be restricted to the addressee or addressee's authorized agent. Advise the clerk or mark the mail piece with the endorsement "Restricted Delivery", . If a postmark on the Certified Mail receipt is desired, please present the arti- cle at the post office for postmarking. If a postmark on the Certified Mall receipt IS not needed, detach and affix label with postage and mail. IMPORTANT: Save this receipt and present it when making an inquiry. PS Form 3800. February 2000 (Reverse) 102595-99-M-2087 Certified Mail Provides: . A mailing receipt . A unique identifier for your mailpiece . A signature upon delivery . A record of delivery kept by the Postal Service for two years lropo inders: . ay ONLY be combined with First-Class Mail or Priority Mail. { available for any class of International mail. ,COVERAGE JS PROVIDED with Certified Mail. For ~sider Insured or Registered Mail. . : a Return Receipt may be requested to provide proof of eturn Receipt service. please complete and attach a Return 811) to the article and add applicable postage to cover the a ilice "Return Ret:eipt Requested". To receive a fee waiver for eturn receipt, a USPS postmark on your Certified Mail receipt is IRENE SHOEMAKER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001-4337 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under 93301 (c) of the Divorce Code was filed on July 17,2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date if filing and service of the Complaint. 3. I consent to the entry of a final decree if 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. 9 4904 relating to unsworn falsification to authorities. Date: to- l's' D -3 ~. (, (1 , Y0l.~~~~~ib~ Irene Shoemaker, Plaintiff ----- -- o ..y ~ 'I p 6' -- . ' <::'> Ji=-. -"" .~ ( " --:' - IRENE SHOEMAKER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001-4337 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER~ 3301(c) AND ~ 3301 (d) 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 if! do not claim them before the 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 is 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. 94904 relating to unsworn falsification to authorities. Date: C 0 - f (A ~ () 3 j:/~~6-Q,~\ Irene Shoemaker, Plaintiff c; , .-- /) IRENE SHOEMAKER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001-4337 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under 93301 (c) of the Divorce Code was filed on July 17,2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date if filing and service of the Complaint. 3. I consent to the entry of a final decree if 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. 94904 relating to unsworn falsification to authorities. Date. ~",.x"""03 ~~~~~&/l4 Jesse Shoemaker, Defendant () c::. 0 C C', " .rJ -<7 ~ '"'!'J ---",,~ n , rn [.: ~ 2_ ~ /' f" I en C' -~' I r:2 f> -~: L:_ - :> , U'1 to ...,,.1 VI ..J t l:-' ,j --:t '::-1 IRENE SHOEMAKER Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001-4337 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER~ 3301(c) AND ~ 3301 (d) OF THE DIVORCE CODE I. 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 if I do not claim them before the 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 is 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. Dat~~.,.~ ~O'::; ~~. (3S.#~#2&/l-?R Jesse Shoemaker, Defendant ----------- ----- (") {.~ .;:;- -L' i' . (.~; \- ~}i_ \:~J :7- / o ~-^i "1 ..- c ( ") . ,. ,"~ '....rl . ~.) -~ - IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001- 4337 CIVIL TERM PRAECIPE TO DISMISS EOUIT ABLE DISTRIBUTION CLAIM To the Prothonotary: Kindly record the equitable distribution count in the Plaintiff's Complaint dismissed. Date: SI2-2../03 7l1irhu/ ~ Michael Parker Certified Legal Intern ~~ccJJi\ ROBERT NS LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001- 4337 CIVIL TERM CERTIFICATE OF SERVICE I, Michael Parker, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Praecipe to Dismiss the Claim for Equitable Distribution on Jesse B. Shoemaker, Defendant, by regular United States mail this '2- 2- day of ~ I "2....a? 3, 2003 at 127 Oak Hill Road, Carlisle, PA 17013. ~~ Michael Parker Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 () c: <.:'~. ur.i~; ....1_' t.tl; -"'7 ~,..-' ~S~ ~. ~~i J>C:. ~ -.; C) (.,,') :;1: :t-"':fa -~ o '-n 1" I") -....~) -~ ".Jt... :.n '.0 IRENE SHOEMAKER, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JESSE SHOEMAKER, Defendant/Respondent 01-4337 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of August, 2001, this matter having been called for hearing, by agreement it is noted as follows: 1. The Defendant/Respondent acknowledges his recent transfer of the 1997 Nissan motor vehicle, which is the subject of this proceeding. 2. By agreement the Defendant/Respondent is enjoined from diposing, transferring, encumbering, concealing, selling, removing or alienating any realty and/or personalty belonging jointly to petitioner and Respondent or purchased by either party during the marriage. 3. The defendant agrees to box-up a certain sewing machine and crafts, and to make them available within one week to Jennifer Neydig. By the Court, Jesse Shoemaker, Pro se 127 Oak Hill Road Carlisle, PA 17013 ~h. //;./ ~ A. Hess, J. ~ ~~ ~ Robert E. Rains, Esquire Michelle L. Anderson, CLI For the Plaintiff/Petitioner IT Volt! gO: z:. ~ z IlvUrf 10 '. ,i - - - IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001-4337 CIVIL TERM INVENTORY OF IRENE SHOEMAKER Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. ~~~~ Plaintiff, Irene Shoemaker ASSETS OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( ) 1. Real Property ( x ) 2. Motor Vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( ) 5. Checking accounts, cash ( ) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trusts ( x ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( x) 11. Gifts ( ) 12. Inheritances 1 RECE\VED Qel 2 22\ln1 ( ) 13. Patents, copyrights, inventories, royalties ( x) 14. Personal property outside the home ( ) IS. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits - severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans ( ) 18. Pension plans (indicate employee contribution and date plan vests) ( ) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits ( x) 24. Debts due, including loans, mortgages held (x) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number Description Of Property Names of All Owners 2 1978 Camper ueneShoemakerand Jesse Shoemaker 2 1983 Box Truck Irene Shoemaker and Jesse Shoemaker 2 1987 Nissan Previously owned by Irene Shoemaker and Jesse Shoemaker 9 Life Insurance Policies Prudential MetLife Jesse Shoemaker 11 Civil War Sword Irene Shoemaker and J esse Shoemaker 11 Lawn Pond Irene Shoemaker and 2 Jesse Shoemaker 11 Lawn Pond Previously owned by Irene Shoemaker and J esse Shoemaker 14 Club Cadet Tractor Previously owned by Irene Shoemaker and Jesse Shoemaker 14 Craftsman Tractor Previously owned by Irene Shoemaker and Jesse Shoemaker 14 Craftsman Tractor Irene Shoemaker and Jesse Shoemaker 14 Tool Shed Irene Shoemaker and Jesse Shoemaker 14 Tools: Irene Shoemaker and Band Saws Jesse Shoemaker Ladders Table Saw Air Compressor 25 2 TVs Irene Shoemaker and Jesse Shoemaker 25 4 VCRs Irene Shoemaker and J esse Shoemaker 25 Furniture Irene Shoemaker and Dining Room Set Jesse Shoemaker Living Room Set Couch Love Seat Chair Recliner King Plus Bedroom Suite 3 25 Appliances Washer & Dryer Microwave Oven Steamer Food Processor Blender Irene Shoemaker and J esse Shoemaker 25 Dishes, Glasses, Pans, Flatware Irene Shoemaker and Jesse Shoemaker 25 Indian Figurines Irene Shoemaker and Jesse Shoemaker 25 Rifle Irene Shoemaker and Jesse Shoemaker 25 Wedding Photographs Irene Shoemaker and Jesse Shoemaker 25 Flowers and swags Irene Shoemaker and Jesse Shoemaker 25 Bar Irene Shoemaker and Jesse Shoemaker 25 Radio Irene Shoemaker and J esse Shoemaker 25 40 Gallon Fish Tank Irene Shoemaker and Jesse Shoemaker 25 2 Milk cans Irene Shoemaker and Jesse Shoemaker 25 Toy Wooden Rocking Cradle Irene Shoemaker and Jesse Shoemaker 4 NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description Of Property Reason for Exclusion 11 Sewing Machine Gift to Irene Shoemaker before marrIage 25 Teddy bear collection Gifts to Irene Shoemaker 25 TV Irene Shoemaker owned before marrIage 25 VCR Jesse Shoemaker owned before marrIage GU Bible books and Encyclopedias ~~~\ Gifts to Jordan Troup (Irene Shoemaker's son) 25 Bookcase Gift to Jordan Troup (Irene Shoemaker's son) PROPERTY TRANSFERRED Item Description Date of Consid- Person to whom Number of Property Transfer eration Transferred 2 1987 Nissan May 2001 Gift Jesse V. Shoemaker 14 Club Cadet Tractor June 2001 $300 Bill Christine 14 Craftsman Tractor June 2001 $150 Bill Christine 14 Lawn Pond June 2001 $100 Bill Christine 5 LIABILITIES Item Description Names of Names of Number of Property All Creditors All Debtors 24 Medical Bill Cumberland Irene Shoemaker $290 Goodwill Fire 24 Medical Bill Holy Spirit Hospital Irene Shoemaker $1111.59 24 Medical Bill Carlisle A.L.S. Irene Shoemaker $466.19 Plaintiff reserves the right to correct and/or supplement this Inventory to the extent that she acquires additional information regarding assets and/or liabilities. 6 .... IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001-4337 CIVIL TERM CERTIFICATE OF SERVICE I, Michelle L. Anderson, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of Plaintiffs Inventory on Jesse Shoemaker, Defendant, at 127 Oak Hill Road, Carlisle, PA 17013, by placing a copy of the same in the United States mail, postage prepaid, this 25th day of October, 2001. ~~MM~ Michelle L. Ande n Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 (') 0 0 c ..- g: ;:-:) -0 r- '-'-} Ii -, to; '-1 ,'" 0 ,,- 2_ ;"'~ r> co ;--. (, ;, + ~" ~'::: ---~ <; -- f'J , ~ c-:"} (/\ .,;,;.~ C~ ~~~: :::) ::<: f ~) C> 0 rJ ~ ~ - . , . . . IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001-4337 CIVIL TERM INVENTORY OF JESSE SHOEMAKER Defendant files the following inventory of all property owned or pcssessed by either party at the time this actlOn was commenced atjd all property t~'iUlsferred within th( preceding three years. Defendant verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein made are subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. ~ 6'-SA'/c::t///?~Il~ Defendant, Jesse Shoemaker ASSETS OF PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. /_ Jo", ('~' . . ..... . @ S~- ~Ac:...tJ w.:..volf )t4l..olvall v .. - \ j 1. Real rroperty 7":' . 'M I'J .vi..,. t - ~....... bd::J. . ( ) 2. Motor Vehicles ,. ~ -I <s~_<) p~ 60\.. ';;;jj Tk-'}f '/714 V .f &a~' /I . zr;:,..g I"D~ ) 3. Stocks, bonds, securities and options ;/#41 I:> 1.o'1J J.k..t." N/'......-- ~ /l/f.'1 t'1"- ~ /Ubi\..C.( ) 4. Certificates of deposit ND'f\.L( ) 5. Checking accounts, cash lv, R fkrv N~ !\i(!1l(, ( ) 6. Savings accounts, money market and savings certificates lv,/'A. /r.kJ,^-" Na111.{J N(;,'\.e..- ( ) 7. Contents of safe deposit boxes I\J()~ ) 8. Trusts NOTV...,( ) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) )JC7i'\..V( ) 10. Annuities NO'tIL( ) 11. Gifts Ivo'^-Li.. ) 12. Inheritances . . A '~n{....; ( IV'; ) 13. Patents, copyrights, inventories, royalties _,_ _~ ( ) 14. Personal property outside the home ~. ~~ ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits - severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans ( ) 18. Pension plans (indicate employee contribution and date plan vests) ( ) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits ( ) 24. Debts due, including loans, mortgages held ( ) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other MARITAL PROPERTY Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number J. Description of Property /97g t!a~(J- Names of All Owners ~s.SL- 6 :5./-I~ lu,^-> -1'il-. . Oh..L~ Rzod &(1 ~:5S<- ~1;<; /S ..s ).I~ ~ -1R . PaId 17. ~~:S#L-~t~-Jj. # () n,;LLf J:b:l DA . ~lpu (/ . -F$~ e~ :S/~t/~wt4 64'L -r~ OIVLg' /:;vct (I'd -!<ss.,L No~ ;) /Q'83 &'Jt: h/M:/ k. 2 /7~7 N.~ c; t:,,' -:rA ~, )/ // t!1 ;.) 1 S;:--Wf) ~d- ---- ~ ?Vd~ G-~;,-~ 10 ~ a.5 tJ &,'~oYt-/:J' . W~.:) &, ~~.......... ;k, ~S<....,4~ ~ )(-5'M~~Ilr- ~.s ,4 G,,(1:: L4-1V.;v ~H.-cL Ol/C rz /1 I-aw~ hvvd- /7' (Y/uo &~r ;1/dvb'V / 1/ 6~/na,o/V ;C;l/1O^" /J ~. > frIiG'~fL,; IL; D.rd--tlS~ It; ~ul"5' ~~~ /~ 700/s ~Q ~ G~ Vt..v- ;; /7J.L., A:;, ~ &, It ;JfL, A 5a~ &ox ---f;~~ :5#~~d/\(~ )~.tt :IlJ\- \ '-;;;vc- =>,4Ivt:W'd~ - /l (/.1 ff ..6?c~ R A4/~~ ~~ P IV<~ ~k~ $4.- ~k. 6V("~ 61c1 ~6.Zv M~ &~d :5?w- Gor Q7 q 'jdl' cL StZl-<- Go r ~fL WC/Y' ~ &0 l r:D yo wo ~ 1<.. ~ fO-r ~f" l. A Lt., ~ ~~ z;:. 2r> ~~~ 5~~ ?~k -1Z:'J $G.- ~ .9/CJ6~ in..- -7i< .. ~<---c. '/;ok,;) tv, w~ S"~ ~( ...vCR :;r l-fa~.2 - ~t.Z~ r~ <sz.4;r-<- :j:" ~ ~-<-'^-^---' -S~ fO () (,(, fI V t'... IZ... a/.. ~ ~~ 'pu..",-" 1/;".r-L - ,D''''''''tJ~.v s;<.,.f' c;.-= w/1k. ~ ~ L-,~, ~ ~nt ~"[ L6u.vt.c... ~t.."j~ ~~ :;;:~T ?v4~ G~v~~ ;I;i,JnL-- lJ.o~ a.. IJ, :etv<3 _ ~c, 1/ ~ ~~$.<. P~.:d ~~ /<. ~ ?/u5 &d~W1 .5&.I1? ~5 ~~'V-{., ~ Jh.<- ,4s a cGj.J6 /-::rv5 ;/h. ~ ?&O-:5 6-, v~ ~ ,)?t-{.- /-VOL u:S La d JJ,/t' ~ J4b~ ~ )/,~ /f;~p~~12.. 15 .. :2 l.\I. ). 0-. 2.5: . . NON-MARITAL PROPERTY Defendant lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: .~ I'J 0 'l of Property ~O .. ~ /). ~~"h 'il /JJIJ<.-I.J I.v hl<-N..-- itDlL. k./~ S4-~ JwT 1k-~' rV6-. I~ ~~"'-' V? ~m& ~,,-r;:,"V Wi:) Mil II (}./r kP5 id~ I ~ Jk., f6~ Description Names of All Owners Item Number /1 ~ ~ --Ii 5><... j .J.~~ 25' )5 ,8,,1;4.... 6@Ks! 6c-dC/~dj~S ~d $'~~ 'b :0/a.. [hv~ tv~..r- S-~ ~/~r -5~ rL jZv-<- 1C~ ~5 8CA::/{l- 6~ /i~ N() T )~ J/IUJ.N--cL" hCL.# " J ~ J,/~ /'VtJi~~ ~r j )>--\_ &/ cI J Jv \ . . . ' . PROPERTY TRANSFERRED Description of Property Date of Transfer Consid- eration Person to Whom Transferred Item Number J I q <(7 ;V>:S~OA- }1rIE(j 1(..1 () i Cl;{c 'SbV\...-- )~ flLtb (lJv--rr;.(U--16~ ~lL r~ <--'-r;JC:r w~ :r tUiS ('>0'7 ~ /"'-0'-'- )"'-..,. 8:11 <v~d 10 "3.(J T~ ~ J;:~ I( ! t!ya/r;~ y;~u12>v j)A/ -r~ k fiu~ /" ~.~ ~/~ J;; -?x ~rt'~ J\~ ~ ~. t I "roR 4;00 ~ M5> .rl 6,~ k 7~S' U/~ ) L) tau/ V\.., .. It. j ,,'" . ~ ... ... .. ...' -. LIABILITIES Item Number Description of Property Names of All Creditors Names of All Debtors / fl.e ~ ~s-r 1 kud-l- ~ fd (L;~ I-'z-s R.(j Y? J---------rf" (}/<- ~v2Y17 -I-- ~~ /cd/l- cJ al/f0vV ~~ /-uoulld /[~V~:l ~ plV ~,li)/ ~ /4 a -k:(o {} 5~G 6<'d-L frvL AtiV /cIelp b&IU~Cv~-t7 .-r;~~ ~ 5I1a/~IlA/V~, , kwJfJ R-'&cv-II'<-S ~A.,",\/ /<.!tltT 10 4t-~-<--l_:t'a~~ 5~p tL~ -r~,vc'~Y-'t 16 ~~ ~)(;~~tJ T/4cvl ~. GC1~~V<: a i jJ'Ti~v"el/L- J ~('J I("~bvv ...~('(~.,. ct,! ~:;''5 c--1;:s c-~~I(.;1'db.>~~ ~=e s~ ~~ ~~ h~& ~-r ~ :7k.? j)~ ~ ~f--r Lv&.:) d/VL-- 1;ff...... /?JdJ'/~ IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE JESSE SHOEMAKER, Defendant : NO. 01-4337 CIVIL TERM CERTIFICATE OF SERVICE I, Michelle L. Anderson, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Inventory of Jesse Shoemaker on Defendant, Jesse Shoemaker, at 127 Oak Hill Road, Carlisle, P A 17013, by placing a copy of same in the United States mail, postage prepaid, this 3rd day of January, 2002. ~y~ ~ichelle L. Andersod'" Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 --- n <;;; o t-J ""'i; p' -/ ~;~' s~'. c> C~', ro--,;) ,- :.,,. \j;' ,/~', -..-\ ..4. ~? c- ('f) <0 ) ?;\~~; y ',;~ -- - ~ ~ .S::' \:P """<:, '~ IRENE SHOEMAKER, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE JESSE SHOEMAKER, Defendant/Respondent : NO. 2001-4337 CIVIL TERM CONSENT AND APPROVAL FOR APPEARANCE UNDER Pa.B.A.R. 322 I hereby consent to the appearance of Michelle Anderson, a Certified Legal Intern under the supervision of an attorney, in the hearing on my Petition for Special Relief before the Honorable Kevin A. Hess at 2:30 p.m. on Friday, August 17,2001. Date: ~- \/- 0 \ {)J\ ~ In ~ ~~{}-Q f\Y\Q kvJ Irene Shoemaker As the supervising attorney for Michelle Anderson, certified under Pa.B.A.R. 322, I approve of her appearance on behalf of the above-named client in the above-named proceeding. S' l f{ - Of 1?&:W Robert E. Rains Supervising Attorney Date: FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 ... . JUL 1 82001{;t' IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 2001- ~1'Jl CIVIL TERM JESSE SHOEMAKER, Defendant RULE TO SHOW CAUSE AND NOW, this ;{YdJ day of ;)u't; ,2001, upon consideration of the within petition, and on motion of Michelle L. Anderson, Certified Legal Intern in the Family Law Clinic, a rule is granted on Respondent to show cause (a) Why he should not refrain from disposing, transferring, encumbering, concealing, selling, removing or alienating any realty and/or personalty belonging jointly to Petitioner and Respondent or purchased by either party during the marriage; (b) And why he should not be required to account for all items of personalty and/or realty sold or disposed of by him since February 13,2001. Rule returnable and hearing the l?tA day of CU~Ja,) t , 200 I, at ~:.3> 0' clock /"Y.m. in courtroom tf of the Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Ad J. j"' '" IRENE SHOEMAKER, Plaintiff/Petitioner : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE ; NO. 2001- z.f:1jJi7 CIVIL TERM JESSE SHOEMAKER, Defendant/Respondent PETITION FOR SPECIAL RELIEF IN THE FORM OF AN INJUNCTION PREVENTING REMOVAL, DISPOSITION, ENCUMBERING OR ALIENATION OF PROPERTY UNDER ~3505(a) OR ~3323(f) OF THE DIVORCE CODE AND Pa. R.C.P. 1920.43(a) I. Petitioner is Irene Shoemaker, an individual residing at 431 North Hanover Street, Apartment I, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondent is Jesse Shoemaker, an individual residing at 127 Oak Hill Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Petitioner and Respondent are husband and wife, having been married on June 26, 1993. 4. Petitioner filed a complaint in divorce seeking equitable distribution on July 17, 2001. 5. Petitioner and Respondent have lived apart since February 13,2001. 6. Respondent has had possession and control of the marital property since the date of separation, which includes, but is not limited to, the marital residence (a trailer being purchased through a rent-to-own agent), a 1978 Camper, box truck, a 1987 Nissan Automobile, three (3) tractors, a tool shed, tools, a Civil War sword, rifles, furniture, electronics, and personal items. 7. Upon information and belief, on or about May 21,2001 Respondent sold the 1987 Nissan, which was marital property, to his son for $300.00. 8. property . Petitioner has also noticed that the 1978 camper has not been on Respondent's 9. Petitioner has also been informed that Respondent may be attempting to sell or dispose of the marital trailer. 10. By removing these items of personalty, Respondent has wrongfully and t ..;1 intentionally prevented Petitioner from exercising her rights and ownership interest in them. 11. Removal of such personalty is to Petitioner's detriment. 12. Immediate and irreparable harm is being caused by Respondent's conduct which is defeating Petitioner's claim of equitable distribution. WHEREFORE, Petitioner prays for equitable relief as follows: (a) that an injunction issue enjoining Respondent from disposing, transferring, encumbering, concealing, selling, removing or alienating any realty and/or personalty belonging jointly to Petitioner and Respondent or purchased by either party during the marriage; (b) that this Honorable Court issue an order requiring an accounting of all items of personalty and/or realty sold or disposed of by Respondent, and that judgment be given to Petitioner against Respondent for monies or property due Petitioner as shown and that no further removal of personalty take place without further Order of this Court; (c) such other relief as this Honorable Court may deem appropriate. Respectfully Submitted, Date Juk117/UxJ L ( Michelle L. Anders n Certified Legal Intern ~l- ( J_ T - S M. PLACil:-" ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 \ '" VERIFICATION I verify that the statements made in this Petition for Special Relief are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to authorities. Date-B~ dO (3001 ~~ ~~GJcw0 Irene Shoemaker, Petitioner \ ',. IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE ~ NO. 2001- ~01J1 CIVIL TERM JESSE SHOEMAKER, Defendant ORDER AND NOW, this day of , 2001, in consideration of Petitioner's Petition for Special Relief in the Form of an Injunction Preventing Removal, Disposition, Encumbering or Alienation of Property and in consideration of Respondent's response to the Rule to Show Cause issued on , 2001, the following ORDER is hereby entered: (1) Respondent is prohibited from disposing, transferring, encumbering, concealing, selling, removing, or alienating any marital property, real or personal, belonging jointly to Petitioner and Respondent or purchased by either party during the marriage. (2) Respondent is further directed to account for all items of personalty and/or realty sold or disposed of by Respondent since February 13, 2001. BY THE COURT, J. IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS OF . : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ~ NO. 2001- ~19f\ CIVIL TERM JESSE SHOEMAKER, Defendant CERTIFICATE OF SERVICE I, Michelle L. Anderson, hereby certify that I am serving a true and correct copy of Plaintiffs Petition for Special Relief in the form of an Injunction Preventing Removal, Disposition, Encumbering or Alienation of Property under g3505(a) or g3323(t) of the Divorce Code and Pa.R.C.P. 1920.43(a) for Plaintiff, Irene Shoemaker, on the following person, the Defendant in the above-captioned matter, by placing the same in U.S. Mail, certified number 70993400001849969480, restricted delivery, return receipt requested, postage prepaid, on the 17th day of July, 2001: Jesse Shoemaker 127 Oak Hill Road Carlisle, P A 17013 Michelle L. Anderso Certified Legal Inte FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 o -- ~ - C>( ..J I.N -t:. QJ:) ~ - FAMILY LAW CLINIC A service to the community by students from The Dickinson School of Law of The Pennsylvania State University The Dale F. Shughart Conununity Law Center 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Fax: (717) 243-3639 May 29,2003 Mr. Robert Elicker Divorce Master's Office Domestic Relations Office 13 North Hanover St. Carlisle, P A 17013 RE: Shoemaker v. Shoemaker Divorce and Equitable Distribution No. 2001-4337 Civil term Dear Mr. Elicker: Please be advised that the Family Law clinic has withdrawn our client's, Irene Shoemaker, claim for Equitable distribution. Enclosed is a copy ofthe Praecipe to Dismiss the Equitable Distribution claim. The parties will now move to finalize the divorce. Thank you for your consideration on this matter. If you have any questions or concerns, please contact the clinic at your convenience. Sincerely, ~~ Michael Parker Certified Legal Intern enclosure cc: Irene Shoemaker PENN STATE .. The Dickinson School of Law An Equal Opportunity University ; IRENE SHOEMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01 - 4337 CIVIL JESSE SHOEMAKER, Defendant IN DIVORCE TO: Family Law Clinic , Attorney for Plaintiff Jesse Shoemaker , Defendant DATE: Thursday, October 17, 2002 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that lS not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. Discovery is incomplete. A pension with Messiah College is being investigated. Also, I am planning to get the property appraised. RECEIVED OCT 2 1 2002 ~ (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. Discovery should be complete by approximately February 28, 2003. II/I ~ J O~ I I DATE j-arf7l/if Low {!;II)IC- cJ~t1} (lfiYt~r wJiL COUNSEl! Ft)R PLAINTIFF (/) COUNSEL FOR DEFENDANT ( ) /dUAttl/11/f?<.... 1-1. J?h<<U<1-/ CcrF-/h'ecl Lf>J<!.1 .J..nfcl'7? PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. NOTE: AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. Oip!/-~} DATE ~5#y.;1,/7{d'u~~ COUNSEL FOR PLAINTIFF ()() COUNSEL FOR DEFENDANT ( ) NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESE~TED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. '16,' Q /PJ.pr"cY. ~:: . r /[~rf'~v1 M~d'Jlort ~ tJ P I" - - ,.... "'\ ..., ,~. t". i..} -t' i..) "', 1.... tJ. ~. - -:- ::;;. ... .~ ... -:- - ~ ~ ~ ~ - -:- .::::; -;:... -;:... - ::;;. ~ -- ~. .-/ o (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF COUNSEL FOR DEFENDANT NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. 4 IRENE SHOEMAKER, Plaintiff v. JESSE SHOEMAKER, Defendant AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA : CIVIL ACTION-LAW DIVORCE : NO. 2001-4337 CIVIL TERM ORDER APPOINTING MASTER ~,rvl & / [,. t: day of t,i C 17) f..Lt", 2002, t. t2~J b 1./- y~lL'C/tetf. Esquire, is appointed master with respect to the following claim: Equitable Distribution of Property. By the Court: 3 \:i 4 \ '.-' - " \'1) ~~l ~,~v' IRENE SHOEMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001-4337 CIVIL TERM MOTION FOR APPOINTMENT OF MASTER Plaintiff IRENE SHOEMAKER moves the 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: 1. The discovery in this case is complete as to the claims for which the appointment of a master is requested. 2. The defendant has appeared in the action personally. 3. The statutory grounds for divorce are 23 Pa.C.S.A. 9 3301 (c) and 23 Pa.C.S.A. 9 3301 (d) with an Equitable Distribution count on behalf of the plaintiff. 4. The action is contested with respect to the following claim: Equitable Distribution of Property. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take Y2 day. o f ;~~~;;- / :::j -, C~ i0 (:::l ~.J ~~ () T1 , ~..<...... h) r:- \0 - Date: 0 e. to he /- "1-, :200 fA J~ II. ~ Suzan H. Rhodes Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 . ... IRENE SHOEMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW DIVORCE JESSE SHOEMAKER, Defendant : NO. 2001-4337 CIVIL TERM CERTIFICATE OF SERVICE I, Suzanne H. Rhodes, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Motion for Appointment of Master on Jesse B. Shoemaker, Defendant, by regular United States mail this '7-th day of d)C/&Jb-e.Jv ,2002 at 127 Oak Hill Road, Carlisle, P A 17013. ~/11U If. i2h {au.- Suzan e H. Rhodes Certified Legal Intern F AMIL Y LA W CLINIC 45 North Pitt Street Carlisle,PA 17013 (717) 243-2968 a (") f:) r-' 1'0 ....-- IV ~:~ ? :-:> 0 -.... n + ...........,; ,...J , , , ',' ..' ~ ::~. _~ _.1 :..'1 h -< c::' ' ' ~ =< ~ ~ IRENE SHOEMAKER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW \is. ]--:() .01 - 4337 CIVIL 19 JESSE SHOEMAKER Iji D]VOECI Defendant ~;Tl\TUS ~;jIEET ])1\'1'1::: hCTIVITIL~;: IRENE SHOEMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 01 - 4337 CIVIL JESSE SHOEMAKER, Defendant IN DIVORCE TO: Family Law Clinic , Attorney for Plaintiff Jesse Shoemaker , Defendant DATE: Thursday, October 17, 2002 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that 1S not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. IRENE SHOEMAKER, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLA.ND COUNTY, : PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE (") c <' -0 i=i' ~~: --::;r-" (;j>: ~r~: :.- '-- ~C. >~:~ PRAECIPE TO DISMISS EOUIT ABLE DISTRIBUTION Cl..AI~ JESSE SHOEMAKER, Defendant : NO. 2001- 4337 CIVIL TERM To the Prothonotary: Kindly record the equitable distribution count in the Plaintiff's Complaint dismissed. Date: S /2-2.../03 '7nirkl ~ Michael Parker Certified Legal Intern C) c,:, -..- ,~.~ __~f': :-'.) r....) v ~.. ':'.rt \0 ~ -< ", ,:; /).. , , %'; /~ ' . , ", , > i."" _/ _ \ \, . I r--.., / i ,(." -- ' ')''\5 L~.) . ,"LV'L' i ...7---'\""'~ _.y' '0.,. /,- '---' {\ - "'" :' ,. ROBERT .I RA'INS LUCY JOHNSTON-WALSH Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968