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Home My WebLink About06-0771 STEPHEN M. KNIGHT, Plaintiff VS. ANNIE A. KROL-KNIGHT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. LL,LC -" CIVIL ACTION - LAW 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. 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, 1 Courthouse Square, 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 LOST 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 SQUARE CARLISLE, PA 17013-3387 (717) 249-3166 c STEPHEN M. KNIGHT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY,I PENNSYLVANIA VS. NO. ANNIE A. KROL-KNIGHT, CIVIL ACTION - LAW Defendant ACTION IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff STEPHEN M. KNIGHT, by his attorney, Herschel Lock, and seeks to obtain a Decree in Divorce from the bonds of matrimony with the above-named Defendant, and avers the following: 1. Plaintiff Stephen M. Knight is an adult individual whose mailing address is in care of Evans Engineering, 2793 Old Post Road, Harrisburg, Dauphin County, Pennsylvania 17110. 2. Defendant Annie A. Krol-Knight is an adult individual residing at 71 Sherwood Circle, Enola, Cumberland County, Pennsylvania 17025. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 27, 1987 in O1dTown, Maine. 5. There have been no prior actions of divorce or annulment between the parties. 6. Defendant is not a member of the Armed Services of the United States or any of its Allies. f 7. Plaintiff has been advised of the availability of counseling, and understands that he has the right to request the Court to require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. The parties have lived separate and apart and at the appropriate time Plaintiff will submit an affidavit alleging the parties have lived separate and apart for a least the time period specified in Section 3301(d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce. COUNT II. REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(a) OF THE DIVORCE CODE 10. The averments of Paragraphs 1 through 9 hereof are incorporated herein by reference thereto. 11. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff respectfully requests the Court to enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. DATED : oil( HERSCHEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 i VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED : ST HEN M. KNI HT t F? C C c ? Q C C ti h ? v ?= c J "T1 iT t jt o ? yn t i _ _7 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN M. KNIGHT, IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. ANNIE A. KROL-KNIGHT, Defendant : NO. 2006-771 CIVIL ACTION -LAW IN DIVORCE MOTION TO WITHDRAW APPEARANCE 1. Petitioner is counsel for Defendant in the above captioned matter, Annie A. Krol- Knight. 2. Defendant's present mailing address is 71 Sherwood Circle, Enola, PA 17025. 3. Defendant also has a significant balance of fees owed and has not made payments as agreed to with Petitioner. 4. Petitioner requests the opportunity to withdraw pursuant to Rule 1.16(b)(4) and (5) of the Pennsylvania Rules of Professional Conduct. 5. Counsel for Plaintiff concurs with this Petition. WHEREFORE, counsel for Defendant requests leave of court to withdraw representation on behalf of ANNIE A. KROL-KNIGHT in the above-captioned matter. Dated: January 30, 2008 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN M. KNIGHT, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-771 ANNIE A. KROL-KNIGHT, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date I served a true and correct copy of the Motion to Withdraw in the above-captioned matter upon the following individual(s) by United States first-class mail, postage prepaid, addressed as follows: Herschel Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 Ms. Annie A. Krol-Knight 71 Sherwood Circle Enola, PA 17025 , DATE: January 30, 2008 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 na Q C P w ANNIE A. KROL-KNIGHT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ; 66--77 -7?771 ( STEPHEN M. KNIGHT, NO. 007-+f'S 2 DEFENDANT PACSES NO. 716102546 ORDER OF COURT AND NOW, this 15t day of February, 2008, upon consideration of the Petition to Withdraw as Counsel filed by the Petitioner, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Plaintiff to show cause why the Petitioner should not be granted permission to withdraw as counsel of record; 2. The Plaintiff will file an answer on or before February 21, 2008; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Plaintiff files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled. 4. The Prothonotary is directed to forward said Answer to this Court. Barbara SumPle-Sullivan Esquire Petitioner --- Annie Krol-Knight, Plaintiff ?rschel Lock, Esquire Attorney for Defendant bas iEs /).Iz I LL a/v/oe By the Court, VINVAIAOSWI- d 6 0 :8 WV ? - 83.E BOOZ AbVIONOi iObd 3KL ?O 30(i4o-CrAlY ti Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN M. KNIGHT, IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. ANNIE A. KROL-KNIGHT, Defendant : NO. 2006-771 CIVIL ACTION -LAW IN DIVORCE AMENDMENT TO MOTION TO WITHDRAW APPEARANCE 1. Pursuant to Rule 208.3(a)2, the Honorable Kevin A. Hess had been assigned to the Protection From Abuse docket regarding the parties. The Honorable Edgar B. Bayley has been assigned to the support docket regarding the parties. WHEREFORE, counsel for Defendant requests leave of court to withdraw representation on behalf of Annie A. Krol-Knight in the above-captioned matter. 16- Dated: February 1 2007 I arbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN M. KNIGHT, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-771 ANNIE A. KROL-KNIGHT, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Laura J. Hughes, Secretary to BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date I served a true and correct copy of the Amendment to Motion to Withdraw in the above-captioned matter upon the following individual(s) by United States first-class mail, postage prepaid, addressed as follows: Herschel Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 Ms. Annie A. Krol-Knight 71 Sherwood Circle Enola, PA 17025 DATE: February 5, 2008 Laura J. Hu , Secr to Barbara Sumple-Sulliv , Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 N O -* - ? -re ?!-i ? 1 CpJ tT+ 1:-, t T; r J} rT, co Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN M. KNIGHT, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. ANNIE A. KROL-KNIGHT, Defendant : NO. 2006-771 : CIVIL ACTION -LAW : IN DIVORCE RULE AND NOW, this day of , 2008 on consideration of the Motion to Withdraw Appearance, a RULE is issued on Plaintiff and Defendant to show cause, if any, why the Court should not grant the relief requested. The Rule is returnable within v days from the date of service hereof. c1r) Q Po C3, • . T v T ?- = Cf? ! s c? r Barbara Sumple-Sullivan, Esquire FILED-OFFICE Supreme Court 43 )23 ) 17 OF THE PROTHONOTARY 549 Bridge Street New Cumberland, PA 17070 2010 NOV 22 AM 11:07 (717) 774-1445 STEPHEN M. KNIGHT, IN -r.J14 1ANg)C QWON PLEAS Plaintiff, CUMl3F UIi?1TY, PENNSYLVANIA v. ANNIE A. KROL-KNIGHT, Defendant NO. 2006-771 CIVIL ACTION -LAW IN DIVORCE MOTION TO WITHDRAW APPEARANCE AS COUNSEL FOR DEFENDANT 1. Petitioner is counsel for Defendant in the above captioned matter, Annie A. Krol- Knight. 2. Defendant's present mailing address is 71 Sherwood Circle, Enola, PA 17025. 3. Petitioner had previously filed a Motion to Withdraw, but Respondent subsequently paid down much of her bill. 4. Defendant has a significant balance of fees owed and has not made payments as agreed to with Petitioner. 5. The case has lain dormant and no significant communication exists between Defendant's counsel and no prejudice would befall Defendant by allowing counsel to withdraw. 6. Petitioner requests the opportunity to withdraw pursuant to Rule 1.16(b)(4) and (5) of the Pennsylvania Rules of Professional Conduct. 7. The prior Judge in this matter was the Honorable Judge Edgar B. Bayley. 8. Plaintiffs counsel has been contacted and concurs in Petitioner's decision to withdraw as counsel. WHEREFORE, counsel for Defendant requests leave of court to withdraw representation on behalf of ANNIE A. KROL-KNIGHT in the above-captioned matter. Respectful Dated: November 18, 2010 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN M. KNIGHT, IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-771 ANNIE A. KROL-KNIGHT, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date I served a true and correct copy of the Motion to Withdraw as Counsel for Defendant in the above- captioned matter upon the following individual(s) by United States first-class mail, postage prepaid, addressed as follows: Herschel Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 Ms. Annie A. Krol-Knight 71 Sherwood Circle Enola, PA 17025 DATE: November 18, 2010 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN M. KNIGHT, Plaintiff, V. ANNIE A. KROL-KNIGHT, Defendant Nov 2 4 2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-771 CIVIL ACTION -LAW IN DIVORCE RULE AND NOW, this A day of N OV C. 1.? , 2010 on consideration of the Motion to Withdraw Appearance as Counsel for Defendant, a RULE is issued on Plaintiff and Defendant to show cause, if any, why the Court should not grant the relief requested. The Rule is returnable within 1%6 days from the date of service hereof. BY THE COURT: Q An, rbgra !5u^iple -??u l/, oo n G rn rn a O rn C" ? cJ O O Cep; cs r^a leof ?? /d ??/D C v c? -O nc O'ri Z Z5 , =C3 vC_- C:) Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN M. KNIGHT, Plaintiff, V. ANNIE A. KROL-KNIGHT, Defendant TO 1FFICE :O :THE PROTHONOTARY 2010 DEC 30 AM, 8' 09 COUNTY IN THE (fflWW4) MON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-771 CIVIL ACTION -LAW IN DIVORCE PETITION TO MAKE RULE ABSOLUTE 1. Petitioner is counsel for Defendant, Barbara Sumple-Sullivan, Esquire. 2. Respondent is Defendant, Annie A. Krol-Knight. 3. Petitioner is requesting allowance to withdraw from the matter due to Respondent's failure to cooperate with the requests of counsel and failure to make payment on her outstanding legal fees. 4. On November 19, 2010, Petitioner filed a Motion to Withdraw her Appearance in this action. 5. On November 24, 2010, the Court issued a Rule returnable in twenty (20) days upon Defendant to show cause why the Motion to Withdraw Appearance should not be granted. 6. The Rule was served upon Defendant and counsel for Plaintiff by regular mail (Delivery Confirmation) by letter dated December 2, 2010. Copies of the Delivery Confirmation receipts are attached hereto as Exhibit A. 7. No timely answer or other response was filed to said Rule by Defendant or counsel for Plaintiff. 8. Petitioner requests that the Rule issued on November 24, 2010 be made absolute and Petitioner shall be allowed to withdraw from the matter. 9. The Honorable Judge M.L. Ebert, Jr. has been assigned to this matter. WHEREFORE, Petitioner requests the Rule be made absolute. DATE: December 27, 2010 %rbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Exhibit A LAW OFFICES BARBARA SUMPLE-SULLIVAN 549 BRIDGE STREET NEW CUMBERLAND, PENNSYLVANIA 170 70-19 31 PHONE (717) 774-1445 FAX (717) 774-7059 December 2, 2010 Ms. Annie A. Krol-Knight 71 Sherwood Circle Enola, PA 17025 Re: Stephen M. Knight v. Annie A. Krol-Knight Docket No. 2006 - 771 Dear Annie: Enclosed constituting service on you is the Rule to Show Cause dated November 24, 2010 entered in the above captioned matter. Barbara Sumple-Sullivan BSS/crs Enclosure U.S. Postal SerVWDMk ry ConffmM l jj6MIpt a- Postage and DWk" man tees MM be paid before n?aifbp, uo A"WSMU(bbeg p-mlldbynid" 1115 Ann'ie A, J: ?I - kn 1 s ?f Sb?e?'?,+,L? Vii, ° ?Lf Ct. i PA 170 s a z o° POSTAL CUSTWER: v° o Postmark Keel) thIS reWPL For its la'y' o Here. Access intemet web s at ru G wwwUVICOM ru or If 1-8oo-222-1//6(6( fp? "' onp?srAtlist 6wy?j o- , M Priodtl? ilwft vift ° ?- Flrat-Class Alk?ll°paroef ? ? PS Font 152, May 2002 P (US Rmm) LAW OFFICES BARBARA SUMPLE-SULLIVAN 549131ZMGE STREET NEW CUMBERLAND, PENNSYLVANIA 17070-1931 PHONE (717) 774-1445 FAX (717) 774-7059 December 2, 2010 Herschel Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 Re: Stephen M. Knight v. Annie A. Krol-Knight Docket No. 2006 - 771 Dear Herschel: Enclosed constituting service on you is the Rule to Show Cause dated November 24, 2010 entered in the above captioned matter. I had indicated in the Petition that you concurred, but the Rule was issued by Judge Ebert anyway. Thank you. If you should have any questions, do not hesitate to contact my office. BSS/crs Enclosure Barbara U.S. Postal ft Mse'blAmy ConRrmataoi RmIpt ru age and Delivery Conflmaw tees must be paid before mailing, ui Ar" Swat Ta (to be compbled by ow"do n, L = 310 -7 ° -risvU, (i'A )-7110 -3 i p C3 POSTAL CU oMER. g o p Keep this recei For Inquiries: C3 Here Access into web site at ? cusps • orcall ?l-801}22 m Q C3 Priprity Maii-Service First-Gass Ma6mvei [?r?r?e services parcel PS Form 152, May 2002 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN M. KNIGHT, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-771 ANNIE A. KROL-KNIGHT, CIVIL ACTION -LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, BARBARA SUMPLE-SULLIVAN, ESQUIRE, do hereby certify that on this date I served a true and correct copy of the Petition to Make Rule Absolute in the above-captioned matter upon the following individual(s) by United States first-class mail, postage prepaid, addressed as follows: Herschel Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 Ms. Annie A. Krol-Knight 71 Sherwood Circle Enola, PA 17025 DATE: December 27, 2010 arbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 R ??.?c ?E?i?? JAN 03 201t ?'! ! ,1r?? ..? Aft ! 1 2 Barbara Sumple-Sullivan, Esquire `' U' 6 C' R LA iI U` 0 0 6N V Supreme Court #32317 ' E N N S YL , ! k, 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 STEPHEN M. KNIGHT, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. ANNIE A. KROL-KNIGHT, Defendant NO. 2006-771 CIVIL ACTION -LAW IN DIVORCE ORDER ?h AND NOW, this y day of T4yv , 20 %1 , upon consideration of the Petition to Make Rule Absolute, said Petition is hereby GRANTED. It is further ORDERED and DECREED that Barbara Sumple-Sullivan, Esquire is hereby released as counsel for Defendant, Annie A. Krol-Knight. BY THE COURT: ?arloo?r?o??umple ? '?IC?va.n ,?, Ne Maw Lock. ESR_ Anne A . Vrol-Knigh4, NOR ?d ?I I M.L. Ebert, Jr. David ED. (Buell 1Protfionotary Office of the Prothonotary Cum6er[and County, (Pennsylvania rkS. Sohonage, T SQ Solicitor 01.1 " 'Y'7/ CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE — THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 C , _A ® (Phone 717 240-6195 0 Ea,c717 240-6573