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Home My WebLink About05-5428VICKI I. STARLIPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION- LAW JACKSON S. STARLIPER, DIVORCE, ALIMONY, AND Defendant EQUITABLE DISTRIBUTION 05- .-qZ(P CIVIL TERM 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 32 South Bedford Street Carlisle, Pennsylvania 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. VICKI I. STARLIPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION- LAW JACKSON S. STARLIPER, DIVORCE, ALIMONY, AND Defendant EQUITA$LE DISTRIBUTION 05- Sal 2 CIVIL TERM COMPLAINT FOR DIVORCE, ALIMONY, AND EQUITABLE DISTRIBUTION The plaintiff, Vicki I. Starliper, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: COUNTI DIVORCE UNDER 23 Pa.C.S. §§3301(a)(6). 3301(c) AND 3301(d) OF THE DIVORCE CODE Plaintiff is Vicki I. Starliper, an individual residing at 221 Shippensburg Mobile Estates, Shippensburg, Cumberland County, PA, since May 1995. 2. Defendant is Jackson S. Starliper, an individual who is currently incarcerated in Franklin County Prison, since August 24, 2005. 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. The plaintiff and defendant were married on May 27, 1995 in Newville, Cumberland County, Pennsylvania. Plaintiff and defendant have lived separate and apart since November 8, 2004. 6. Defendant has been physically abusive towards Plaintiff and a Protection From Abuse Order was issued as a result of the abuse, No. 04-5754, on November 8, 2004. 7. There have been no prior actions for divorce or for annulment between the parties. The marriage is irretrievably broken. 9. 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 of divorce. COUNT II ALIMONY 10. Plaintiff repeats and realleges paragraphs one through nine. 11. Plaintiff requires support to adequately maintain herself according to a reasonable standard of living. 12. Plaintiff was not substantially employed during the marriage. 13. Plaintiff suffers various medical problems which prevent her from working at this time. 14. Defendant is financially able to provide for his reasonable needs and the reasonable needs of the Plaintiff. WHEREFORE, Plaintiff requests the Court to enter an award of reasonable alimony, and such other relief as the Court deems just. COUNT III EQUITABLE DISTRIBUTION 15. Plaintiff repeats and realleges paragraphs one through fourteen. 16. Plaintiff and Defendant have acquired property during the marriage, including, but not limited to: a) A trailer located at 221 Shippensburg Mobile Estates, Shippensburg, PA. b) A pension and/or retirement benefits from Letterkenny. WHEREFORE, Plaintiff requests the Court to enter an award for equitable distribution of property, and such other relief as the Court deems just. Respectfully Submitted, Date XRRECOPP Certified Legal Intern LUCY J HIl TON-WALSH Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 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 unworn falsification to authorities. Date(OW lo, 6 6 Plaintiff Vicki I lip r VICKI I. STARLIPER, Plaintiff V. JACKSON S. STARLIPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW DIVORCE, ALIMONY, AND EQUITABLE DISTRIBUTION 05- S42P CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Vicki I. Starliper, 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. Respectfully submitted, Date BRENDA COPP Certified Legal Intern L Y/ OHNSTON-WALSH Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 r^ - C'7 ` cr " (- -t _ t-: ','' G, :, - . i - ?... s VICKI 1. STARLIPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION- LAW JACKSON S. STARLIPER, DIVORCE, ALIMONY, AND Defendant EQUITABLE DISTRIBUTION 05-5428 CIVIL TERM AFFIDAVIT OF SERVICE I, c u , hereby certify that I am a competent adult and that I served a true and correct copy of the Complaint for Divorce on the Defendant, Jackson Starliper, at the Franklin County Prison, 625 Franklin Farm Lane, Chambersburg, Franklin County, Pennsylvania. Service was complete upon receipt by Jackson Starliper on the -A i? day of C 2005. 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: ~?C?/ YK? Name <-? N ' i-? a C :a ; + il -. ,, . . ? i'• ,. ' ? t . C:? .. n i u. ?_.. ? ??i ?J ? _ '' , , _ : L ? .:'I it +_ l -? cr: Vicki Starliper, Plaintiff V. Jackson Starliper, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 05-5428 CIVIL TERM AFFIDAVIT OF SERVICE I, Charla Corwin, Certified Legal Intern, hereby certify that I served, via United States Mail, First Class, postage prepaid, a true and correct copy of the Inventory of Plaintiff, on Defendant, Jackson S. Starliper, at 38 North Penn Street, Shippensburg, Pennsylvania, 17257 on June 27, 2007. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge 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: 7 OL Q ? ??') Charla Corwin Certified Legal Intern t•a ? f, '. -,O F3 J tfi c; VICKI I. STARLIPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - DIVORCE JACKSON S. STARLIPER, Defendant : NO. 05-5428 CIVIL TERM INVENTORY OF PLAINTIFF, VICKI I. STARLIPER 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, to the best of her knowledge, information, and belief. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. --a , ? t'/' 4-e2.? - Plaintiff, Vicki I. Star riper 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. (X) 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 ( ) 11. Gifts ( ) 12. Inheritances ( ) 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 (X) 18. Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plans, Individual Retirement Accounts (X) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. Military/V.A. benefits ( ) 23. Education benefits ( ) 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 Description Names Of Number Of Property All Owners 1 221 Shippensburg Mobile Estates Vicki I. Starliper Shippensburg, PA Jackson S. Starliper 2 1988 Chevrolet Camaro 1980 Chevrolet Minivan 9 Life Insurance Policy Jackson S. Starliper From Letterkenny Current Beneficiary: Vicki Starliper 18/19 Pension/Retirement Benefits Jackson S. Starliper From Letterkenny 2 . 20 Disability Benefits 25 Household Furnishings: Computer, Two Television Sets, VCR, DVD Player, Entertainment Center, Microwave, DVD and Videotape Collection, and Commemorative Coin Collection. PROPERTY TRANSFERRED Item Description Date Of Number of Property Transfer Consideration Vicki I. Starliper Vicki I. Starliper Jackson S. Starliper Person To Whom Transferred LIABILITIES Item Description Names Of Names Of Number of Property All Creditors All Debtors 1 221 Shippensburg Mobile Estates Green Tree Servicing, LLC Vicki I. Starliper Shippensburg, PA Jackson S. Starliper 3 NON-MARITAL PROPERTY Item Description Number of Property Reason For Exclusion Owner from Marital Property Plaintiff reserves the right to correct and/or supplement this Inventory to the extent that she acquires additional information regarding assets and/or liabilities. 4 C) " t7 f l R, } rrt t C7 . Ta Vicki I. Starliper, Plaintiff/Petitioner V. Jackson S. Starliper, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE : NO. 05 - 5428 PETITION FOR RULE TO SHOW CAUSE WHY DEFENDANT SHOULD NOT BE COMPELLED TO FILE AN INVENTORY The Plaintiff, Vicki I. Starliper, by her attorneys, the Family Law Clinic, petitions this Court to issue a Rule to Show Cause why Defendant shall not be compelled to file an Inventory pursuant to Pa.R.C.P. 1920.33. In support of her Petition, Vicki I. Starliper states as follows: 1. Parties were married on May 27, 1995. 2. Plaintiff filed a complaint in divorce with an Equitable Distribution count against Defendant on October 18, 2005. 3. On June 27, 2007, Plaintiff served on Defendant an Inventory of all property owned and possessed by Plaintiff and asked Defendant to respond with his own Inventory. 4. Defendant failed to file his own Inventory. 5. Pursuant to Pa.R.C.P. 1920.33(a), each party shall file an inventory specifically describing all property owned or possessed at the time the action was commenced. Pursuant to Pa.R.C.P. 1920.33(c), if a party fails to file an inventory, the court may make an appropriate order under Pa.R.C.P. 4019(c) governing sanctions. 6. As of this filing date of this Motion, Defendant has failed to provide the Family Law Clinic with his Inventory. 7. Defendant is not represented by counsel, therefore no concurrence of opposing counsel was sought under C.C.R.P. 208.2(d). 8. The court is advised, pursuant to C.C.R.P. 208.3(a)(2), that no Judge has previously ruled on this docket for divorce. However, the Honorable Judges Hess and Bayley have ruled on the parties' ancillary issues of spousal support and protection from abuse, respectively. WHEREFORE, Plaintiff, Vicki I. Starliper, respectfully request that this Honorable Court issue a Rule to Show Cause why the Defendant should not be compelled to file his Inventory within twenty (20) days. Respectfully Submitted, Date Oci 01,3 '&v 0?? Charla Lenz Certified Legal Intern Robert ns Thomas M. Place Lucy Johnston-Walsh Megan Reismeyer Anne MacDonald-Fox THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Counsel for the Plaintiff ?? ? ?-[1 ..,.a ? ?.''? ? ...rA ?? ?? (_7 l.?l ?.j `•v Y ^ ?f • v ?t OCT s 1 2007 Vicki I. Starliper, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - DIVORCE Jackson S. Starliper, Defendant/Respondent : NO. 05 - 5428 ORDER AND NOW, this 2e day of ??*a?.?...t.er-- , 2007, upon consideration of the foregoing petition, it is hereby ordered that 1. a rule is issued upon the Defendant to show cause why the Plaintiff is not entitled to the relief requested; 2. the Defendant shall file an answer to the petition within twenty (20) days of service of this Order upon the Defendant; 3. the petition shall be decided under Pa.R.C.P. 206.7; 4. notice of entry of this order shall be provided to all parties by Plaintiff/Petitioner. BY THE COURT, J. ? 0? y ?y Abv r t Vicki Starliper, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Jackson Starliper, Defendant NO. 05 - 5428 CIVIL TERM CERTIFICATE OF SERVICE I, Charla Lenz, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Order on the Petition for Rule to Show Cause Why Defendant Should Not be Compelled to File an Inventory on Jackson Starliper, residing at 38 V2 North Penn Street, Shippensburg, PA, 17257, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Jackson Starliper, on the 14th day of November 2007 as evidenced by the attached green card. N ' CM N 0 Ln ru m ru m 0 0 0 0 Ir M a Ln 0 o ? D- o Nr N 3 L m LL T Z M 3 " LL N a Charla Lenz Certified Legal Intern Megan Riesmeyer Anne MacDonald-Fox Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ra Q r,. {D 0 r_ - to rn • • ?r Cl) ti Vicki I. Starliper, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Jackson S. Starliper, Defendant/Respondent : NO. 05- 5428 CIVIL TERM PETITION TO MAKE RULE ABSOLUTE PURSUANT TO Pa.R.C.P. Rule 206.7 AND NOW, comes Petitioner, Vicki I. Starliper, by her attorneys, the Family Law Clinic, and files this Petition to Make the Rule issued on November 2, 2007 Absolute and states as follows: On October 18, 2005, Plaintiff filed a Divorce Complaint pursuant to Rule 3301(a)(6), (c) and (d) of the divorce code, in which she requests equitable distribution of the parties' marital assets. (A copy of that Divorce Complaint is attached as Exhibit "A".) 2. On October 28, 2005, Defendant was served a copy of the Divorce Complaint. 3. On June 27, 2007, the Plaintiff filed her Inventory. 4. On October 30, 2007, the Plaintiff filed A Rule to Show Cause Why Defendant Should Not Be Compelled to File an Inventory (attached hereto as "Exhibit B"). 5. On November 2, 2007, the Honorable Kevin A. Hess issued a Rule upon Defendant directing him to show cause why he should not be required to File an Inventory. The Order directed Defendant to respond within twenty (20) days of service of the Order upon him (A copy of the November 2, 2007 Order is attached as Exhibit "C".) 6. Plaintiff s counsel served a copy of the November 2, 2007 Order on Defendant on November 14, 2007. 7. Twenty (20) days have passed since service of the rule to show cause Order upon Defendant, and he has filed no response to that Order. 8. Plaintiffs counsel has not sought concurrence of opposing counsel pursuant to Local Rule 208.3(a) because Defendant has no counsel of record in this matter. WHEREFORE, Petitioner requests this Court to Make the Rule issued on November 3, 3007 absolute and direct Jackson S. Starliper, Defendant, to file an Inventory pursuant to Pa. R.C.P. 1920.33 within thirty (30) days. ate: Date:- Respectfully Res ectfully Submitted, Charla Lenz Certified Legal Intern Anne NhrPbnahf-Fox Megan Rie meyer Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA. 17013 (717) 243 -2968 Fax: (717) 243-3639 Vicki I. Starliper, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Jackson S. Starliper, Defendant/Respondent : NO. 05- 5428 CIVIL TERM CERTIFICATE OF SERVICE I, Megan M. Michael, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of Plaintiff's Petition to Make Rule Absolute, on Mr. Jackson S. Starliper residing at 38 '/2 N. Penn Street, Shippensburg, Pennsylvania, 17257 by depositing a copy of the same in the United States mail, postage prepaid on December 11, 2007. Mean M. Michael Certified Legal Intern A it Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 :: -? _. t. ?-:'a _ .?.,, ri ° ?-,? c ? . ? ? __,? _?,.. ? ? ,: i.: • • =? ?'• - :ta ? ?_ . ?? DEC 1 22007')4 Vicki I. Starliper, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V.. : CIVIL ACTION - LAW IN DIVORCE Jackson S. Starliper, Defendant/Respondent : NO. 05- 5428 CIVIL TERM ORDER OF COURT AND NOW, this t Y' day of A",( • , 2007, a rule to show cause having been issued upon Defendant and no answer having been filed, it is hereby Ordered that Defendant Jackson S. Starliper shall file an Inventory pursuant to Pa. R.C.P. 1920.33 in the above matter within thirty (30) days of the date of this order. By the Court, Date Judge Fltk --{ FFIC; OF THE PR(Y M, , 7TRF3Y 2007 DEC 17 AM 10: 5 5 INTY PENNSYLVANA Vicki I. Starliper, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Jackson S. Starliper, Defendant/Respondent :NO. 05- 5428 CIVIL TERM CERTIFICATE OF SERVICE I, Megan M. Michael, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Court's Order directing the Defendant to file an Inventory, on Mr. Jackson S. Starliper at 38 I/Z N. Penn Street, Shippensburg, Pennsylvania, 17257 by United States Mail, postage prepaid, on December 19, 2007. !Z {q- 0-7 Date Me &M. Michael Certified Legal Intern Megan4Riesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 c CT ? T7+' 9 33 , ±I7 } --E) C Vicki I. Starliper, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Jackson S. Starliper, Defendant/Respondent :NO. 05- 5428 CIVIL TERM PETITION FOR CIVIL CONTEMPT FOR DISOBEDIENCE OF A COURT ORDER The Petitioner, Vicki I. Starliper (Wife), by counsel, hereby petitions this Court for Civil Contempt and respectfully requests that this Court find the Defendant, Jackson S. Starliper (Husband), in contempt of the Court's December 14, 2007 Order and in support thereof respectfully represents the following: 1. On October 18, 2005, Wife filed a Divorce Complaint pursuant to Rule 3301(a)(6), (c) and (d) of the Divorce Code, Title 23, in which she requested equitable distribution of the parties' marital assets. 2. On October 28, 2005, this office served the Husband with a copy of the Divorce Complaint. 3. On June 27, 2007, Wife filed her Inventory. 4. On October 30, 2007, Wife filed A Rule to Show Cause Why Defendant Should Not Be Compelled to File an Inventory. 5. On November 2, 2007, the Honorable Kevin A. Hess issued a Rule upon Husband directing him to show cause why he should not be required to File an Inventory. The Order directed Husband to respond within twenty (20) days of service of the Order upon him. 6. Wife's counsel served a copy of the November 2, 2007 Order on Husband on November 14, 2007. 7. Twenty (20) days passed since service of the rule to show cause Order upon Husband, and he filed no response to that Order. 8. On December 14, 2007, the Honorable Kevin A. Hess issued an Order directing Husband to file an inventory within thirty (30) days of service of the Order upon him. (A true and correct copy of the Court's Order of December 14, 2007, is attached hereto as Plaintiffs Exhibit A, and incorporated herein by reference.) 9. Wife's counsel served a copy of the December 14, 2007 Order on Husband on December 19, 2007. 10. Thirty (30) days passed since service of the rule to show cause Order upon Husband, and he has not filed his inventory to date. 11. Wife's counsel has not sought concurrence of opposing counsel pursuant to Local Rule 208.3(a) because Husband has no counsel of record in this matter. WHEREFORE, due to Defendant's failure to comply with the Order of Court dated December 14, 2007, Plaintiff requests that this Honorable Court order that: a. The Defendant be held in contempt of the Court's December 14, 2007; b. Pursuant to Pa.R.Civ.P. 1920.33(c) and 4019(c), assess the Defendant a fine of $50/day, commencing May 2, 2008, for each and every day after May 2, 2008, that the Defendant fails to file his inventory. C. The Plaintiff be awarded any other relief this Court deems equitable and dust. Date: 1 Respectfully submitted, Ruchika &ipW Certified Legal Intern MEGA, RIESMEYER THOMAS M. PLACE ROBERT E. RAINS ANNE MACDONALD-FOX Supervising Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION I verify that the statements made in this Petition 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. uchi a Certifie Legal Intern Vicki I. Starliper, Plaintiff/Petitioner V. Jackson S. Starliper, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 05- 5428 CIVIL TERM CERTIFICATE OF SERVICE I, Ruchika Gupta, hereby certify that I am serving a true and correct copy of the Petition for Civil Contempt for Disobedience of Court Order and sanctions under Pa.R.Civ.P. 1920.33(c) and 4019(c) on this date by first class United States Mail postage pre-paid on Jackson Starliper at 38'/2 N. Penn Street, Shippensburg, PA 17257. Date: C l ? Ruchika Gupta Certified Legal Intern MEGAN'RIESMEYER THOMAS M. PLACE ROBERT E. RAINS ANNE MACDONALD-FOX Supervising Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Vicki I. Starliper, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Jackson S. Starliper, Defendant/Respondent : NO. 05- 5428 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Vicki I. Starliper, 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 ?1 l S ?c'i3 R ctfull mitted, uchik Ciu a Certified Legal Intern ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 VICKI I. STARLIPER, P laintiff/Petitioner vs. JACKSON S. STARLIPER, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-5428 CIVIL ORDER AND NOW, this "R' day of April, 2008, a rule is issued on the defendant/respondent to show cause why he ought not to be cited in contempt of court. This matter to be heard on Wednesday, May 14, 2008, at 11:00 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. BY THE COURT, / 'W 1-4k Hess, J. V Ruchika Gupta, CLI Family Law Clinic 'X Jackson Starliper 38 1/2 N. Penn Street Shippensburg, PA 17257 rlm 1 OF THE r P. 2003 APR 2 1 a lip. 3 J Vicki Starliper, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION-LAW Jackson Starliper , Defendant NO. 05- 5428 CIVIL TERM CERTIFICATE OF SERVICE I, Nicole Berman, Certified Legal Intern, Family Law Clinic, hereby certify that the Family Law Clinic served a true and correct copy of the Order of Court Scheduling a Hearing on Mr. Jackson Starliper, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid addressed to 38 %2 North Penn Street, Shippensburg, Pennsylvania, 17257. Service was complete upon receipt by Mr. Jackson Starliper, at 107 North Washington Street, Apartment 1, Shippensburg, Pennsylvania 17257, on the 25 h day of April 2008 as evidenced by the attached green card. i ole Berman Certified Legal Intern Anne ld-Fox Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 A L N ¦ Complete items 1, 2, and 3. Also complete ftem 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 mailpieae, or on the front if space permits. X Signature V Article Addressed to: Q%a /Y6 P-6 i-v n &4-,-LRt J11, c?st? I Received by (Pdnred !lame) 0. D?ate/° D ,??SkSa•G s s7h??? 7 C D. is delivery address different from item 17 .rte If YES, enter delivey address below- ? No /07 Al aihlog6f, Ct A -7,:,?s7 3. 1yps Mall ? Express Md ? Regmered 214tatum Receipt for ? imured mail ? C.O.D. 4. Restricted Dellvery7 (Extra Fee) MR 7005 0390 0003 2632 6987 ( ps Form 3811, February 2004 Domeatlc Elshrn 102595 02-M t54Q C a rti, VICKI STARLIPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW JACKSON STARLIPER, Defendant NO. 05-5428 CIVIL TERM IN RE: PETITION FOR CONTEMPT ORDER OF COURT AND NOW, this 14th day of May, 2008, it appearing that the defendant has signed a release with respect to his pension information, by agreement of the parties, the pending contempt citation is dismissed without prejudice to the plaintiff to refile the petition in the event that the release is withdrawn. By the Court, `""I Kevi A. Hess, J. Ms. Nicole Berman Certified Legal Intern Anne MacDonald-Fox, Esquire Family Law Clinic For Plaintiff Mr. Jackson Starliper 107 N. Washington Street Apartment 1 Shippensburg, PA 17257 pr. 6F :bg iVINVAIASi NAd r? 6 *Z Wd 91 IN 8001 AdVLO vCOIL' `.W ?H1 1Q