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HomeMy WebLinkAbout05-5464 MICHELE SCHAEFER, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA ; No. 20(;5'- 59(,,'-1 Civil Term ALAN B. SCHAEFER, Defendant : ACTION IN DIVORCE 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 LA WYER 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 MICHELE SCHAEFER, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. !J .5-, -!i-II t.- 'f Civil Term ALAN B. SCHAEFER, Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE COUNT I - DIVORCE I. Plaintiff is Michele Schaefer, a competent adult individual, who has resided at 49 Leni Lane, Cheekcowhea, NY, 14225 since July 18,2005. 2. Defendant is Alan B. Schaefer, a competent adult individual, who has resided at 2132 Canterbury Drive, Mechanicsburg, Cumberland County, Pennsylvania, since 1998. 3. Defendant has been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 26, 1990 in Buffalo, New York. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have three children together; namely, Morgan Schaefer, date of birth 7/24/93; Matthew Schaefer, date of birth 3/8/95; Christopher Schaefer, date of birth 12/26/97. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) that the marriage is irretrievably broken pursuant to 23 Pa.C.S. 3301(c); (b) that Plaintiff has suffered such indignities as to render her condition intolerable and life burdensome pursuant to 23 Pa.C.S. 3301(a)(6). WHEREFORE, Plaintiff requests the court to enter a decree in divorce. COUNT II - EOUlTABLE DISTRIBUTION OF PROPERTY 11. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property . WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. Respectfully submitted, D"" (O/tq/o,,- e Adams, Esquire LD. No. 79465 64 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verifY that the statements made in this Complaint 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: ltJ!/Q 10- ~.14!~L If, '~A1?'{' ichele Schaefer, Plainti ' ~ ~ ~ @; (;1j::. f';:- ~, ~ (J ~ - -11 0 ~ C") -l - (,) --I ~ r;- d --,1 ri-j -!:> ~ _I::> " \.-':,:: ~ v,- ~ -F ..[) ~ ::t:> !~'? t- ~ r,-'o-) ~ c' t <>-- --- vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. D;- ~ 5[../0 L I Civil Term ACTION IN DIVORCE MICHELE SCHAEFER, Plaintiff ALAN B. SCHAEFER, Defendant AFFIDAVIT OF SERVICE AND NOW, this October 25,2005, I, Jane Adams, Esquire, hereby certifY that on October 20,2005, a certified true copy of the NOTICE TO DEFEND and COMPLAINT IN DIVORCE was served, via certified mail, restricted delivery, return receipt requested, addressed to: Alan B. Schaefer 2132 Canterbury Dr. Mechanicsburg,Pa.17055 DEFENDANT . 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 penn its. 1. Article Addressed to: ~6.~b, "2.:l3 2. ~""""()~ ~ 3. Service Type .... .\' ~rtified Mall 0 Express MiU ~ bv..- 1 'A 0 Regis'e"'d 0 Return R:e;pt for Me",handise ~ 17 0 Insured Mail 0 C.O.D. OS5 4. Restricted Delivery? (Extra Fee) ~s . D. Is delivery address different from ite~.-:D..1" ~. ~~. If YES, enter delivery address b~~S~~.I;:'" / '('/ . . /r:-,' 1.(,,"" '.' < i'",-< i::;". ";', " 2. Article Number (Transfer from service label) , PS Form 3811, February 2004 7004 1350 0003 7288 4868 Domestic Return Receipt 102595-Q2.M-1540 Respectfully Submitted: Clil2e~ ./ ~ / u.R-. /(:) J e Adams, Esquire , . . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF r<:~ c, , ; (.:' MICHELE SCHAEFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2005 - 5464 Civil Term ALAN B. SCHAEFER, Defendant ACTION IN DIVORCE PLAINTIFF'S PETITION FOR SPECIAL RELIEF I. Plaintiff is Michele Schaefer, (hereinafter referred to as "Wife"), who has resided at 49 Leni Lane, Cheektowaga, NY, 14225 since July 18,2005. 2. Defendant is Alan B. Schaefer, (hereinafter referred to as "Husband"), who currently resides in the marital home at 2132 Canterbury Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Husband and Wife were married on May 26,1990 in Buffalo, New York; however, they resided in Mechanicsburg, Pennsylvania, during the course of their marriage. 4. A divorce was filed under the above-captioned number on October 19, 2005. 5. Plaintiff and Defendant have three children together; namely, Morgan Schaefer, age 12, Matthew Schaefer, age 10, Christopher Schaefer, age 7; the children currently reside with Wife in Cheektowaga, New York. 6. After Wife left the marital home, on July 18, 2005, she contacted Husband to request certain items of personal property, such as the children's furniture from the marital home. A list of such items is attached as Exhibit A. 7. The children are currently sleeping on mattresses and futons since they are not in possession of their bedroom furniture. 8. The marital home is currently titled in Husband's name alone. After Wife requested personal items from Husband, the parties were unable to reach an agreement allowing Wife to obtain the items. After the parties were unable to agree, Husband said he would call the police if Wife came to the home to get the items. 9. On or about November 30, 2005, after Wife made yet another request for the personal items, Husband said "everything that is important to you is gone." 10. On the evening of December 5, 2005, Husband said that he was going to contact an auctioneer to auction off the contents of the marital home. 11. Wife currently has no access to the marital home. Wife is extremely concerned that items of personal property may be removed or destroyed. 12. If Husband removes or sells all property in the home, it will be impossible to have an inventory and appraisal completed. 13. The marital home is currently listed for sale with Realtor Pat Burke. 14. To date the parties have had no offers on the marital home. Wife would like to reduce the listed sales price, but Husband refuses to do so. 15. Wife is requesting that the Court: a. Order Husband to provide Wife with the items listed on Exhibit A within thirty (30) days so that the parties' children will have adequate sleeping arrangements and their personal possessions. b. Order Husband to not dispose of or move any items in the home. c. Order Husband to allow a certified appraiser in the home within ten (10) days so that an inventory may be made and that the items in the home may be appraised. d. Order Husband to cooperate with the Realtor and accept her recommended price for listing the marital home. e. Order that all proceeds from any sale of the marital home be held in escrow until further agreement of the parties or Order of Court. WHEREFORE, Wife prays this Honorable Court enter an Order providing the relief requested. Respectfully submitted, Date: 12 - )6- <-->:JS- ., ams, Esquire . 79465 4 uth Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF Schaefer v. Schaefer Petition for Special Relief December 16, 2005 EXHIBIT A Children's items: Morgan's bedroom set and room contents, Matthew's bedroom set and room contents Christopher's cedar chest and night stand plus contents of room (not bed or dresser), Bed linens and comforters for children's beds, Basketball net, Morgan's downstairs room furniture, any toys that belong to the children, any clothes that still remain in the house. Items that were Michele's before marriage: Three tier table in living room, contents of curio cabinet (teacups, decanter, crystal, eggs), Pink crystal, china and contents of china cabinet, Rocking chair in family room, small table at the top of the stairs, oak table in master bedroom with four chairs, baby dresser in master bedroom. Items that were gifts to Michele: Lennox lamp in living room, curio cabinet, Christmas dishes Other items requested: One of the three couches or the wing back chair. 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. S4904 relating to unsworn falsification to authorities. Date: \ 2- ~ (.;-' - V ~s.----"'" '.....J...x /) ;' .. I ,'}--171 ('7 i . I ,,~ I Michele Schaefer, Plain' o c :.?; -::"J(")" T1"r": ;~'; . , ~~. (/.! r~i 1 '-~ 5.:~.' ~.: :&-;:,:c! ~ ...., ~ = .c,......, o r'1 n o " :r:n mc- -Om :o\...,.) C)(.~ ~,--<! ^) ~~~ :::~ "~:J :.< \.0 -0 ::& f';! W \D MICHELE SCHAEFER, Plaintiff vs. ALAN B. SCHAEFER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2005 - 5464 Civil Term : ACTION IN DIVORCE ORDER AND NOW, this "2 'l."" day of ;lX.... 1..,- , 2005, upon consideration of Plaintiff's Petition for Special Relief, a RULE is hereby issued upon respondent, Alan B. DEe 2 1 zoo~~J Schaefer, to show cause, if any he should have, why the relief requested in the attached petition should not be granted. RULE RETURNABLE within upon Alan B. Schaefer. cc: Jane Adams, Esquire Alan B. Schaefer, Defendant 2-0 days of servic(: of this Order and Petition ..4J J. J) )7. AS (J d (/+-r.LL4 .~ pi> ,cry ..."""') C') ~:;;::: c... N '" ,-' Ld = - " C L..~ C":;:l (;;':;1 C'~ ~.~ G MICHELE SCHAEFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2005 - 5464 Civil Term ALAN B. SCHAEFER, Defendant ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this January 24, 2006, I, Jane Adams, Esquire, hereby certifY that on January 4, 2006, a certified true copy of the PETITION FOR SPECIAL RELIEF was served, via certified mail, return receipt requested, addressed to: Alan B. Schaefer 2132 Canterbury Drive Mechanicsburg, Pa. 17055 DEFENDANT . 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 mail piece, or on the front if space permits. 1. Article Addressed to: 1lo.1an Scha~er 2132 Canterryurv Dr ~echanicsryurq ?1lo. 17055 o Agent o Addressee C. Date of Delivery D. Is delivery address different from Item 1? 0 Yes If YES. enter deliVery address below: 0 No l~~ Q...-' '" . .:ryJ S\servi ype / I 'l:irCertlfied tv'!,alJ~-'~ Express Mail o R~ered; 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (fransfer from service lat 7005 0390 0003 2635 3921 PS Form 3811, February 2004 Domestic Return Receipt 0spe;::sun~hwe-._ ~ J Adams, Esquire -- h . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 102595..o2-M-1540 (,.-~ -~......... ~]- -;:. -- {.,.~ ....:::) _.,./._--,--------- MICHELE SCHAEFER, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2005 - 5464 Civil Term ALAN B. SCHAEFER, Defendant ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this January 24, 2006, I, Jane Adams, Esquire, hereby certiry that on January 10,2006, a certified true copy of the RULE TO SHOW CAUSE was served, via certified mail, return receipt requested, addressed to: Alan B. Schaefer 2132 Canterbury Drive Mechanicsburg,Pa.17055 DEFENDANT SENDER: COMPLETE THIS SECTION . Complete items 1, 2, and 3. Also complete item 4 jf 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 an the front if space permits. 1. Article Addressed to: Alan "3 Schaefer 2132 Canterbury Dr M~ch~nicsburq p~ 17055 :3. Service Type ~ertified Mail o Registered o Insured Mail o Express o Return Receipt for Merchandise Dc.o.o. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service label' 7DD5.D39!LDDD3 ,~635 3976 10259S..o2-M-1540 PS Form 3811 , February 2004 Domestic Return Receipt Kespectfully Submitted: -, ~ & Jt Adams, Esquire . . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF _..,-----------~.._.... -.. <: ~,) -_1 \.;:; MICHELE SCHAEFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2005 - 5464 Civil Term ALAN B. SCHAEFER, Defendant ACTION IN DIVORCE MOTION TO MAKE THE RULE AND NOW COMES, Michele Schaefer, by and through her attorney, Jane Adams, Esquire, and represents the following: 1. Plaintiff is Michele Schaefer, (hereinafter referred to as "Wife"), who has resided at 49 Leni Lane, Cheektowaga, NY, 14225 since July 18, 2005. 2. Defendant is Alan B. Schaefer, (hereinafter referred to as "Husband"), who currently resides in the marital home at 2132 Canterbury Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. On or about December 19'\ 2005, Plaintiff filed a Petition for Special Relief requesting that: a. Husband provide Wife with the items listed on Exhibit A within thirty (30) days so that the parties' children will have adequate sleeping arrangements and their personal possessions. b. Husband not dispose of or move any items in the marital home. c. Husband allow a certified appraiser in the home within ten (10) days so that an inventory may be made and that the items in the home may be appraised. d. Husband cooperate with the Realtor and accept her recommended price for listing the marital home. e. All proceeds from any sale of the marital home be held in escrow until further agreement of the parties or Order of Court. 4. On December 22, 2005, a Rule was issued upon Defendant, to show cause, if any, why the relief requested should not be granted. (Please see Exhibit B). 5. Counsel for Plaintiff served a copy ofthe Petition and the Rule upon Defendant via certified mail. (Affidavits of Service regarding the Petition and the Rule are attached as Exhibit C and D). 6. In addition, Plaintiff visited the marital home since the filing of the petition and noticed that many items had been removed from the marital home; she believes they may have been placed in storage units. 7. As of January 30, 2006, Counsel has not received any response regarding the petition as to why the Rule should not be granted. WHEREFORE, Jane Adams, Esquire, respectfully requests this Honorable Court to make the Rule absolute and grant the relief requested in the above-captioned matter. Respectfully Submitted, Date: 1-30- D (" _~7-- Schaefer v. Schaefer Petition for Special Relief December 16, 2005 EXHIBIT A Children's items: Morgan's bedroom set and room contents, Matthew's bedroom set and room contents Christopher's cedar chest and night stand plus contents of room (not bed or dresser), Bed linens and comforters for children's beds, Basketball net, Morgan's downstairs room furniture, any toys that belong to the children, any clothes that still remain in the house. Items that were Michele's before marriage: Three tier table in living room, contents of curio cabinet (teacups, decanter, crystal, eggs), Pink crystal, china and contents of china cabinet, Rocking chair in family room, small table at the top of the stairs, oak table in master bedroom with four chairs, baby dresser in master bedroom. Items that were gifts to Michele: Lennox lamp in living room, curio cabinet, Christmas dishes Other items requested: One of the three couches or the wing back chair. ~X\tlE>n-- A- \ !.lEG 2, '" ZOU5 rl1\ MICHELE SCHAEFER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 2005 - 5464 Civil Term ALAN B. SCHAEFER, Defendant : ACTION IN DIVORCE ORDER AND NOW, this ).) NL day of ~~, 2005, upon consideration of Plaintiffs Petition for Special Relief, a RULE is hereby issued upon respondent, Alan B. Schaefer, to show cause, if any he should have, why the relief requested in the attached petition should not be granted. RULE RETURNABLE within ,) 0 days of service of this Order and Petition upon Alan B. Schaefer. /9. J. ~~.!l>~. f cc: Jane Adams, Esquire Alan B. Schaefer, Defendant Tfl!'~ ','>", '" 'VI;; \,-,,'L,.'I ,!"\';',t'V',' 'C't::.","'ORD I T ~. ~ L lI...5~\J~ U'~r.'~'tJ I1tlS!ilnr'!1 ji WiUmiil! il'''' . "".. ,'00 1l'Ie ." .. .., '., "U; (') Imlo Stli my hall(l J .Sija/ 01 said Court CarliSIG, Pa, AXJ"[ ~ f; MICHELE SCHAEFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2005 - 5464 Civil Term ALAN B. SCHAEFER, Defendant ACTION IN DIVORCE C) ,.. , , "c. (,_. :-,-~ AFFIDA VIr OF SERVICE i.," r...) AND NOW, this January 24, 2006, I, Jane Adams, Esquire, hereby certifY that ...,-~ on January 10, 2006, a certified true copy of the RULE TO SHOW CAUSE was served,:vja c_, <..D ,. , certified mail, return receipt requested, addressed to: Alan B. Schaefer 2132 Canterbury Drive Mechanicsburg, Pa. 17055 DEFENDANT . Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address 6n 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: Alan 13 Schaefer 2132 Canterbury Dr MechanicsburqPA 17055 3. Service Type ~ertlfied Mall D Express o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from servfce laber... 70.05,.039[:1 ,:00,0326.35 3979.-, .' .'..... PS Form 3811, February 2004 Domestic Return Receipt Kespectfully Submitted: {Q 02- ;! ,rl Adams, Esquire ~. . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 102595"02-M-1540 S><tt11S1J C' MICHELE SCHAEFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANl1p ._~, , ~.~. vs. No. 2005 - 5464 Civil Term f'.,) ALAN B. SCHAEFER, Defendant ACTION IN DIVORCE AFFIDAVIT OF SERVICE ~ .", ,,--.~-; AND NOW, this January 24, 2006, I, Jane Adams, Esquire, hereby certifY that on January 4,2006, a certified true copy of the PETITION FOR SPECIAL RELIEF was served, via certified mail, return receipt requested, addressed to: Alan B. Schaefer 2132 Canterbury Drive Mechanicsburg, Pa. 17055 DEFENDANT . Complete items 1, 2, and 3. Also complete item 41f 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: Alan Schaefer 2132 Canterburv Dr ~echanicsburq Pl\. 17055 X B. Recel~"by (Printed Name) o Agent o Addressee C. Date of Delivery D. Is delivery address different from It 1? DYes If YES, enter delivery address below: 0 No /.:":;/ 3:. -Servl ype " ~Certlfied ~~<f: Express Mall o "R~stermi ,~,." . 0 Return Receipt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from servIce fat 7005 0390 0003 2635 3921___ PS Form 3811, February 2004 Domestic Return Receipt ( es~e~tfullY su(~ttet '_/ tl\Q L^-O~3--- (J Adams, Esquire , 10 . . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 102595-02-M-154C eXt-h fS l \ b CERTIFICATE OF SERVICE AND NOW, this January 30, 2006, I, Jane Adams, Attorney for Plaintiff, Michele Schaefer, hereby certifY that a copy of the MOTION has been duly served upon the following parties, by placing such in the custody ofthe United States Postal Service, via certified mail, postage pre-paid addressed to: Alan B. Schaefer 2132 Canterbury Dr. Mecharricsburg,Pa.17055 DEFENDANT 64 South Pitt St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF n ~ c c;;,,> 0 ,~:-~ ,'.i'" -0 1-;"' ,- .--1 ::c.,,~ ,- ~.: filiI' Lv -rJrn 'ur;.:' :~ ,::j -V i.~_?~~ ::c '::-~fri ~) ., , ,- ~D - -.0 -< ~ FE-tJ 0 IlDU6 4\'0 MICHELE SCHAEFER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2005 - 5464 Civil Term ALAN B. SCHAEFER, Defendant ACTION IN DIVORCE AND NOW, this Z. -:! day of f;.,6vv"J , 2006, upon consideration of Plaintiff's Petition for Special Relief, it is hereby ORDERED and DECREED: a. Husband shaH provide Wife with the items listed on Exhibit A within thirty (30) days so that the parties' children wiH have adequate sleeping arrangements and their personal possessions. b. Husband shaH not dispose of or move any items in the marital home. c. Husband shall aHow a certified appraiser in the home or to any other place where the marital property is located, such as a storage unit, within ten (10) days so that an inventory may be made and that the items may be appraised. d. Husband shaH cooperate with the Realtor and accept her recommended price for listing the marital home. e. AH proceeds from any sale of the marital home be held in escrow until further agreement of the parties or Order of Court. cc: Jane Adams, Esquire , Alan B. Schaefer, Defendant "~ J .~ ,2,02.01.- ~. ,"--~,','n,", ---,'\'! h..J S I : II IN 2- 8JJ g[jGl AtJ\iJ.Oi\GH~()ad 3Hl :10 T)iYO.0311:l MICHELE SCHAEFER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 200S - 5464 Civil Term ALAN B. SCHAEFER, : ACTION IN DIVORCE Defendant PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: AND NOW, this I~ day of ~ please mark the abOve-captioned case discontinued an~ended. ,2006, Respectfully Submitted, Date: III q /0 C e Adams, Esquire . No. 79465 4 S. Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~;, f'^)