Loading...
HomeMy WebLinkAbout02-1339IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN R. CRAIG, PLAINTIFF CIVIL ACTION-LAW -VS- NO. STEWART P. CRAIG, DEFENDANT IN DIVORCE a v.m. NOTICE TO DEFEND AND CLAIM RIGHTS TO: Stewart P. Craig, Defendant 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 at the Cumberland County Court House, 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. Pennsylvania Bar Association-Lawyer Referral Service Telephone 1-800-692-7375 (PA only) or 717-238-6715 The Court of Common Pleas of Franklin 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 the Prothonotary's Office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend any scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN R.. CRAIG, PLAINTIFF -vs- CIVIL ACTION-LAW NO. 102 - 1339 1. icxl ?Z ?'1 STEWART P. CRAIG, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE Count I IRRETRIEVABLE BREAKDOWN 1. Plaintiff is Colleen R. Craig, an adult individual, who currently resides at 507 Meadow Drive Shippensburg, Cumberland County, Pennsylvania, where she has resided since October of 2001. 2. Defendant is Stewart P. Craig, an adult individual, who currently resides at 85 Sawmill Road, Newburg, Cumberland County, Pennsylvania, where he has resided for the past year. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The plaintiff and defendant were married on February 14, 1997, at Shippensburg, Cumberland County. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that marital counseling may be requested and that a list of marriage counselors is available in the office of the Cumberland County Prothonotary. Plaintiff has further been advised of the right to request that the Court require the parties to participate in marital counseling. 8. Plaintiff requests the Court to enter a decree of divorce. COUNT II EQUITABLE DISTRIBUTION 9. The prior paragraphs in this Complaint are incorporated herein by reference thereto. 10. Plaintiff and defendant have acquired property, both real and personal, during their marriage. 11. Plaintiff and defendant have been unable to agree as to an equitable distribution of said property. 12. Plaintiff requests the Court to equitably divide, distribute and assign the marital property between the parties as provided by Section 3502 of the Divorce Code. Date: , 2002 Carrie M. Bowmaster, Esquire Attorney for Plaintiff Reichard Law Offices, LLC ID #70226 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. f 4904, relating to unsworn falsification to authorities. Date: 3 2002 C teen R. Crai NNI w?ccc?? L' J C ;s, : C^) y -? V7 `-- - l17 ? ? i..:l- ??. V Q C-- rn -G I. ,. ? . 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN R. CRAIG, PLAINTIFF CIVIL ACTION-LAW s -vS- NO. 02-1339 CIVIL TERM STEWART P. CRAIG, DEFENDANT IN DIVORCE a v.m. PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the above-captioned Divorce Complaint pursuant to Pa.R.C.P. Sec. 401(b). A copy of the original complaint is attached hereto. A Carrie M. Bowmaster, Esquire Reichard Law Offices, LLC Attorney for Plaintiff Dated: 2002 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN R. CRAIG, PLAINTIFF CIVIL ACTION-LAW -VS- NO. 02 _ LL& /? C:'ud ?Ml STEWART P. CRAIG, DEFENDANT IN DIVORCE a v.m. NOTICE TO DEFEND AND CLAIM RIGHTS TO: Stewart P. Craig, Defendant 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 at the Cumberland County Court House, 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. Pennsylvania Bar Association-Lawyer Referral Service Telephone 1-800-692-7375 (PA only) or 717-238-6715 The Court of Common Pleas of Franklin 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 the Prothonotary's Office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend any scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN R. CRAIG, PLAINTIFF CIVIL ACTION-LAW -vs- NO. STEWART P. CRAIG, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE Count I IRRETRIEVABLE BREAKDOWN 1. Plaintiff is Colleen R. Craig, an adult individual, who currently resides at 507 Meadow Drive Shippensburg, Cumberland County, Pennsylvania, where she has resided since October of 2001. 2. Defendant is Stewart P. Craig, an adult individual, who currently resides at 85 Sawmill Road, Newburg, Cumberland County, Pennsylvania, where he has resided for the past year. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The plaintiff and defendant were married on February 14, 1997, at Shippensburg, Cumberland County. 5. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. 6. 7. Plaintiff has been advised that marital counseling may be requested and that a list of marriage counselors is available in the office of the Cumberland County Prothonotary. Plaintiff has further been advised of the right to request that the Court require the parties to participate in marital counseling. 8. Plaintiff requests the Court to enter a decree of divorce. COUNT II EQUITABLE DISTRIBUTION 9. The prior paragraphs in this Complaint are incorporated herein by reference thereto. 10. Plaintiff and defendant have acquired property, both real and personal, during their marriage. 11. Plaintiff and defendant have been unable to agree as to an equitable distribution of said property. 12. Plaintiff requests the Court to equitably divide, distribute and assign the marital property between the parties as provided by Section 3502 of the Divorce Code. Date:, 2002 ?c'-e-? / Carrie M. Bowmaster, Esquire Attorney for Plaintiff Reichard Law Offices, LLC ID #70226 Y 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. f 4904, relating to unswom falsification to authorities. Date: 3 -, 2002 n Colleen K Crai ' (71 1 _..._ ? ( 17_ L,,J cz: . ? Ii.LJ 1 L G C'?! ? 7 U IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH COLLEEN R. CRAIG, Civil Action -Law Plaintiff vs. F.R. No. 02-1339 Civil Term STEWART P. CRAIG, Defendant In Divorce a.v.m. VERIFICATION OF SERVICE I, CARRIE M. BOWMASTER, ESQUIRE, the attorney for the Plaintiff, Colleen R. Craig, in the above-captioned action, did serve a true and correct copy of the Complaint in Divorce on Defendant, Stewart P. Craig, by serving him United States First Class mail, postage pre-paid, Certified, Restricted Delivery, on May 6, 2002, at his address of 85 Old Sawmill Lane, Newburg, Pennsylvania, copy of the original Return Receipt is attached hereto. I verify that the statements 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. Carrie M. Bowmaster, Esquire Attorney for Plaintiff • 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 ST?,'l, W A-z ? • l21ZA<Z1 l gS QL? ??f1LtlL t?+l.aX-." ?e w'bu?-ter ?A tlattb RESTRICTED DELIVERY A. S ure X f ? Agent ? Adds; B. Received by (Printed Name) 7t f Deli e,x 1- . Ccat " F • C D. Is de livery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type ,%Jl4penified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extre Fee) 2. Arkle Number • :. '!- (rr&-WW from aervke abet) Z p p 4 Z. cry 5 PS Form 3811, August 2001 Domestic Return Receipt 1025es-o1-M-25oa v5t r ` 1 n , ? ?}rrl ? ? e r?J IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN R. CRAIG, Plaintiff CIVIL ACTION - LAW vs- STEWART P. CRAIG, Defendant NOTICE No. 02-1.339 Civil Term IN DIVORCE a v.m. If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(D) OF THE DIVORCE CODE 1. The parties to this action separated on August 11, 2001 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities Date: 1 B Ol/Ir+ Colleen . Cr ' , Plaintiff CERTIFICATE OF SERVICE I hereby certify that on this D'Jday of S te", 2003, I served a true and correct copy of the foregoing document via United States mail, first class, postage pre-paid on the following: Steward P. Craig 85 Old Sawmill Lane Newburg, PA 17240 By: Douglas R. Roeder, Esquire Reichard Law Offices, LLC 70 West King Street Chambersburg, PA 17201 (717) 267-2288 Z c O n t iy n Tl C _]7 "4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN R. CRAIG, CIVIL ACTION - LAW Plaintiff -vs- No. 02-1339 Civil Term STEWART P. CRAIG, Defendant IN DIVORCE a v.m. COUNTER-AFFIDAVIT OF CONSENT UNDER SECTION 3301(D) OF THE DIVORCE CODE TO: STEWART P. CRAIG, Defendant 1. Check (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: _(i) The parties to this action have not lived separate and apart for a period of at least two (2) years. _(ii) The marriage is not irretrievably broken. 2. Check (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. _(b) I wish to claim economic relief, which may include alimony, division of property, lawyers' fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth in the Notice of Intention to Request a Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Steward P. Craig NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE, AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. CERTIFICATE OF SERVICE j I hereby certify that on this ? day of , 2003,1 served a true and correct copy of the foregoing document via United States mail, first class, postage pre-paid on the following: Steward P. Craig 85 Old Sawmill Lane Newburg, PA 17240 By: ?. ?Jwl ? Douglas R. Roeder, Esquire Reichard Law Offices, LLC 70 West King Street Chambersburg, PA 17201 (717) 267-2288 L"? 'Tl 'n t 571 G .. ? r .r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN R. CRAIG, CIVIL ACTION - LAW Plaintiff -vs- No. 02-1339 Civil Term STEWART P. CRAIG, Defendant IN DIVORCE a v.m. PETITION TO WITHDRAW AS COUNSEL FOR PLAINTIFF NOW COMES, Douglas R. Roeder, Esquire, your Petitioner and Attorney for Colleen R. Craig. Undersigned counsel avers as follows in support of his petition to withdraw: Your Petitioner is Douglas R. Roeder, Esquire of Reichard Law Offices, LLC, 70 West King Street, Chambersburg, PA 17201. Your Respondent is Plaintiff Colleen R. Craig, residing at 507 Meadow Drive, Shippensburg, PA 17257. Respondent retained Reichard Law Offices, LLC to represent her the above captioned divorce matter. 4. Respondent has made no attempts to reconcile her outstanding bill of $1,232.87 with Reichard Law Offices, LLC. 5. Respondent has made no payments on her account balance since June 11, 2003 despite numerous letters and telephone calls. 6. Respondent is not willing or is unable to reconcile her account or to provide a retainer to move this case forward. A divorce has been filed, however there are no actions pending with the Court or the Divorce Master. Defendant Stewart P. Craig, in the in the above captioned divorce matter, is not represented by an attorney. 9. Undersigned counsel has attempted to contact Stewart P. Craig and was unable to reach him. Therefore, it is presumed that he does not concur. WHEREFORE, I, Douglas R. Roeder, Esquire, respectfully request that this Honorable Court enter the attached Order granting a rule to show cause why, Douglas R. Roeder, Esquire should not be allowed to withdraw from the representation of Colleen R. Craig. Respectfully submitted, r Douglas R. Roeder, Esquire Supreme Court ID #80016 70 West King Street Chambersburg, PA 17201 (717) 267-2288 VERIFICATION I verify that the statements made in this Petition to Withdraw are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unswom falsifications to authorities. Douglas R. Roeder, Esquire CERTIFICATE OF SERVICE l day of March 2004 I served a true and correct copy of the I certify that on this V foregoing document via United States mail, first class postage pre-paid on the following: Colleen R. Craig 507 Meadow Drive Shippensburg, PA 17257 Stewart P. Craig 85 Old Sawmill Lane Newburg, PA 17240 By: Douglas R. Roeder, Esquire Reichard Law Offices, LLC 70 West King Street Chambersburg, PA 1701 (717) 267-2288 w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN R. CRAIG, Plaintiff -vs- STEWART P. CRAIG, Defendant CIVIL ACTION - LAW No. 02-1339 Civil Term IN DIVORCE a v.m. AND NOW, this 2 Y'day of ? A! i , 2004 upon consideration of the foregoing Petition to Withdraw as Counsel for Plaintiff, it is hereby ordered that: (1) a rule is issued upon the Respondent to show cause why the Petitioner is not entitled to the relief requested; (2) the respondent shall file an answer to the petition within twenty (20) days of this date; (3) the petition shall be decided under Pa.R.C.P. No. 206.7; (4) If no response is filed within twenty (20) days, petitioner may withdraw upon Praecipe. (5) Argument or depositions will be considered only upon request. NOTICE OF THE ENTRY OF THIS ORDER SHALL BE PROVIDED TO ALL PARTIES BY THE PETITIONER BY THE COURT: X?l J. bA 03, ?" ?lN?/AIASNNdd AiNnoo Zh:9 Wv 90 Hvw"a ALIVL?XCRIOHd 3Hl d0 ZUji0-o-mu IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN R. CRAIG, CIVIL ACTION - LAW Plaintiff -vs- No. 02-1339 Civil Term STEWART P. CRAIG, Defendant IN DIVORCE a v.m. PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of undersigned counsel on behalf of the Plaintiff Colleen R. Craig, in the above-captioned matter. Respectfully submitted, Q4. e. &&-" Douglas R. Roeder, Esquire Supreme Court ID #80016 70 West King Street Chambersburg, PA 17201 (717) 267-2288 CERTIFICATE OF SERVICE I certify that on this ? day of April 2004, I served a true and correct copy of the foregoing document via United States mail, first class postage pre-paid on the following: Colleen R. Craig 507 Meadow Drive Shippensburg, PA 17257 Stewart P. Craig 85 Old Sawmill Lane Newburg, PA 17240 c By: ily C. Ddy s, for Douglas R. Roeder, Esquire 70 West King Street Chambersburg, PA 1701 (717) 267-2288 O Qp t "i7 2ti. Ty t = N r y?s7 V -? COLLEEN R. CRAIG, Plaintiff V. STEWART P. CRAIG, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 2002-1339 CIVIL ACTION-LAW IN DIVORCE PRAECIPE Please enter my appearance on behalf of Colleen R. Craig, the Plaintiff in the above captioned matter. Date: -s - z- at, Hannah Herman-Snyder, Esqw5re GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ? ?? A ? e.? o =+ a COLLEEN R. CRAIG, Plaintiff V. STEWART P. CRAIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1339 CIVIL ACTION LAW IN DIVORCE PETITION FOR APPOINTMENT OF MASTER AND NOW comes Plaintiff, Colleen R. Craig, by and through her attorney of record, Hannah Herman-Snyder, Esquire, and requests the Court appoint a Master with respect to the following claims: (x) Divorce (x) Distribution of Property () Annulment () Support () Alimony (x) Counsel Fees (x) Costs and Expenses () Alimony Pendente Lite and in support of her Petition states: 1. Discovery is complete as to the claims for which the appointment of a Master is requested. 2. The Defendant is not represented by counsel. 3. The statutory grounds for divorce are 23 Pa.C.S.A. §3301(c) and 23 Pa.C.S.A. §3301(d). 4. This action is contested with respect to all claims. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one day. 7. Additional information, if any, relevant to the motion: None. Respectfully submitted, N `t QAP tu" SAM?Au\ Hannah Herman-Snyder, Esquirb Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 COLLEEN R. CRAIG, Plaintiff V. STEWART P. CRAIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1339 CIVIL ACTION LAW IN DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the I 1 th day of September, 2006, cause a true and correct copy of the foregoing document to be served upon the interested parties as follows by first class mail, postage prepaid: DATE: ': - t 1- 0 4 Stewart P. Craig 85 Old Mill Road Newburg, PA 17240 ???r Hannah Herman-Snyder, Esqu re Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant IN DIVORCE PETITION FOR ECONOMIC RELIEF: COUNSEL FEES AND COSTS AND NOW comes Petitioner, Colleen R. Craig, by and through her counsel of record Hannah Herman-Snyder, Esquire, and the law firm of Griffie & Associates and petitions this Honorable Court as follows: 1. Plaintiff is Colleen Craig, an adult individual currently living at 260 Airport Road, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Stewart P. Craig, an adult individual currently residing at 85 Old Mill Road, Newburg, Cumberland County, Pennsylvania. 3. The parties hereto are husband and wife, having been joined in marriage on February 14, 1997. 4. The parties separated on or about August 11, 2001. 5. Plaintiff filed a Complaint in Divorce on or about May 19, 2002. 6. Plaintiff is requesting reasonable counsel fees and costs. WHEREFORE, Plaintiff requests this Honorable Court order Defendant to pay Plaintiff's counsel's reasonable fees and costs. Respectfully Submitted, Hannah Herman-Snyder, Esqu e Griffie and Associates 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: p Y CO LEEN R. COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the l Ith day of September, 2006, cause a true and correct copy of Plaintiff's Petition for Economic Relief: Counsel Fees and Costs to be served upon Defendant by first-class mail, postage prepaid at the following address: Stewart P. Craig 85 Old Mill Road Newburg, PA 17240 DATE: <.ti - I t o LE vTt (ii\..t?CI A ?.l_ 0 ?1YhL: bl Sd Irii?L C?3\ Hannah Herman-Snyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 r? J :7::6 Al P 1 t/N ts 2• i i SEN. i COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, Defendant CIVIL ACTION LAW IN DIVORCE ORDER APPOINTING MASTER AND NOW this t`i"'"day of , 2006, E. Robert Elicker, II, Esquire, is appointed Master with respect to the following claims: Divorce, Costs and Expenses, Counsel Fees and Distribution of Property. BY THE COURT, W?cm J. tT F 1 iG et ASS04: 10. es cc: Hannah Herman-Snyder, Esquire Attorney for Plaintiff ,,?tewart P. Craig Pro Se o? 0 < ?; ,, '?.?? ?` "?? ' `?? ? ? a ?-:?.. ??` ? w ?: COLLEEN R. CRAIG, Plaintiff V. STEWART P. CRAIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-1339 CIVIL ACTION LAW IN DIVORCE PETITION FOR APPOINTMENT OF MASTER AND NOW comes Plaintiff, Colleen R. Craig, by and through her attorney of record, Hannah Herman-Snyder, Esquire, and requests the Court appoint a Master with respect to the following claims: (x) Divorce (x) Distribution of Property () Annulment () Support () Alimony (x) Counsel Fees (x) Costs and Expenses () Alimony Pendente Lite and in support of her Petition states: 1. Discovery is complete as to the claims for which the appointment of a Master is requested. 2. The Defendant is not represented by counsel. 3. The statutory grounds for divorce are 23 Pa.C.S.A. §3301(c) and 23 Pa.C.S.A. §3301(d). 4. This action is contested with respect to all claims. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one day. 7. Additional information, if any, relevant to the motion: None. Respectfully submitted, scums Qn_r r?- sum dt Hannah Herman-Snyder, Esquirb Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 • - -t COLLEEN R. CRAIG, Plaintiff V. STEWART P. CRAIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1339 CIVIL ACTION LAW IN DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the 1 Ith day of September, 2006, cause a true and correct copy of the foregoing document to be served upon the interested parties as follows by first class mail, postage prepaid: Stewart P. Craig 85 Old Mill Road Newburg, PA 17240 DATE: 9-11-014 Hannah Herman-Snyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 ,_ ? ?-..7 - _. ~ r r? , r ca'? s F v", ?_ '?{ ?i?? ? _ C.-^, C:b COLLEEN R. CRAIG, Plaintiff/Petitioner V. STEWART P. CRAIG, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 2002-1339 CIVIL ACTION-LAW IN DIVORCE PETITION FOR SPECIAL RELIEF: FORCE SALE OF MARITAL REAL ESTATE AND NOW comes Petitioner, Colleen R. Craig, by and through her attorney of record Hannah Herman-Snyder, Esquire, and the law firm of Griffie & Associates and petitions this Honorable Court as follows: 1. Petitioner is the above named Plaintiff, an adult individual currently residing at 260 Airport Road, Shippensburg, Cumberland County, Pennsylvania. 2. Respondent is the above named Defendant, an adult individual currently residing at 85 Old Sawmill Road, Newburg, Cumberland County, Pennsylvania. 3. The parties separated on or about August 11, 2001. 4. Petitioner filed a Divorce Complaint on March 19, 2002, which was reinstated on April 19, 2002 and served on May 6, 2002. 5. Undersigned counsel was retained on or about September 13, 2005 and since that time has made repeated attempts to contact Respondent, who has never been represented by legal counsel, by way of written correspondence, in order to resolve the parties' equitable distribution issues. 6. Petitioner, through counsel, has incurred additional counsel fees and costs by having a constable serve Respondent with correspondence to ensure that Respondent was in receipt of attempted negotiations from counsel. 7. Petitioner had prior counsel, who made like attempts to contact Respondent, to no avail. 8. The parties are joint owners of real estate located at 85 Old Sawmill Lane. A copy of the deed is attached hereto and incorporated by reference as Exhibit "A." 9. Respondent has resided on said real estate since the parties' separation. 10. Said real estate is owned by the parties, free of any liens against the property. 11. For at least the past two years, Petitioner has had to pay the real estate taxes for the property as Respondent has made no effort to do so, even though Respondent has had exclusive possession of the premises. 12. The real estate was scheduled for Sheriff s Sale during the summer of 2006 as the taxes for 2004, due and owing to the Tax Claim Bureau of Cumberland County, remained outstanding. 13. Petitioner paid the taxes for 2004 on August 11, 2006. A copy of said receipt is attached herein and incorporated by reference as Exhibit "B". 14. A Section 3301(d) affidavit was filed on September 24, 3003 and no response or counteraffidavit has been filed. 15. Petitioner filed a Petition for Appointment of Master on September 11, 2006 and on September 14, 2006 E. Robert Elicker, II, Esquire, was appointed as Master to resolve claims of divorce, costs and expenses, counsel fees, and distribution of property. 16. A Pre-Hearing Conference was held on January 2, 2007 at 9:30 a.m. and Respondent did not attend, nor did Respondent file a Pre-Trial Statement as required. 17. A hearing is scheduled in front of the Master for February 22, 2006. 18. At the suggestion of the Master, Petitioner is filing this Petition with the Court as it is anticipated that Respondent will not appear for the hearing scheduled for February 22, 2006, which will likely necessitate a rescheduling of the hearing to assure no question of service and notice arise in this matter. 19. In order to expedite this matter, Petitioner requests this Honorable Court issue a Rule to Show Cause on Respondent as to why she should not be allowed to unilaterally list the house for sale and sign all necessary documents associated with the sale of the house on behalf of herself and Respondent. WHEREFORE, Petitioner requests this Honorable Court grant Petitioner permission, unilaterally, to sell the real estate at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania and hold the proceeds with undersigned counsel until such time as the Master can hear the rest of the equitable distribution issues and distribute the proceeds accordingly. Respectfully Submitted, r- Hannah Herman-Snyder, E ` uire Attorney for Petitioner GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 # 3 ? 4-27-06; E : 56AM ; CDS LTk'.l' ;772624351 2/ ::.:LEA DEEDS UDEILA:ID COUNTY-W ?y THISDEED MADE the,4."4?' day of In the year of two thousand (2000), BETWEEN, LINDA K. 880 H„'s le woman, of Pennsylvania, hereinafter referred to as the Grantor, AND, SMART P. CRAIG and CDLLEN RAE CRAIG, husband and wife, of Pennsylvania, hereinafter referred to as the Grantees, WITNESSEM, that in conslderatlon of the sum of One ($1.00) Dollar, in hand paid, the receipt whereof, is hereby acknowledged, the said Grantor does hereby grant and convey to the sold Grantees, their heirs and assigns: ALL that certain lot or tract of land, together with the Improvements erected thereon, known and designated as Lot No. I on the hereinafter referred to subdivision plan, situate In HopewellTownship, Cumberland County, Pennsylvania, bounded and described as follows: B Q at a conaete rnomwwnt set at the nord westeriv rrM comer of the wNW desaW lot and set In Bne of lards now or formerly of john 7. E ' ClIppinger; thence along brie of lard now or funnerly of join J. Oippfiger, North 61 degnees 39 ftwl es 20 seconds East, 277.05 feet to an adsbv stub in stones, the comer of the within described lot and comer of lands now or formerly of Sohn J. CVpinger, nrow or formerly of Harry 1. Swartz and now or formerly of Cvorge A. hoover, t,erroe along Ow of lairds now or fomwty of George A. Hoover, South 24 degrM 53 rtUrn M-14 seconds East, 504.93 fleet to an Iron pin in Woof lands of PenruAvania TUrnp>foe Gornnisslon; thence Wong lien of lands row or farmerlir of Pwmylvarfa Tumpl a Cainmissiorr, South 76 o degrees 58 minutes 13 seconds West, 282.58 feet to an try pin at corner of other lands now or fome* of the Gary D. Jests and Bev&* June GWwft i now Beverly )care Hardy, thence along Lot No. 2 as shown on the aforesaid plan, North 24 degrees 53 minaAes 14 semrrds iMest, 43515 fleet to the point and place of BEGINNMW. CON TADOiG a WI area of 3" acres. The above description Is in accordance with subdivision plan entitled "Land Subdivision for Lucy E. Testes" recorded August 7, 198S, In Cumberland THIS IS A CONVEYANCE FROM PARERr 70 CH= AND SPOUSE AND IS THEREFORE TRANSFER UK Eim">P[. bow 226 PAGE 66,5 EXHIBIT 4-27-06; 6:S5AN4;CDS LTKY ;7172624351 BE= that Sarno real estate afar Gary 0. ]esi>a Ma Bme*/ 3une Gbnvft, now, Beverly Am Hwdy, by th* dead datmf March 26,1987 acid recorded In the Office of iht Recorder of Leeds In and t v CrKrt WWW Cwty, Pe m syMauio, in Deed Book OW, V(*mm 33 at Page 745, oorneyed to OSM Bechtel and Lk Wa K. Betfibd, hLvsbarnd and wft said Owar Berl died on thereby vesting (W mid mawlete tole to Undo aL 9ed tiei, Grantor herein. The above described lot is sn6ject to an eidstbng 16 tout right of way and a 50 toot wide dedicated dght of way along the southerly property ihne and exberrdhng the M wtlth of the lot AND the said GmW will spedally warrant the property hereby conveyed. IN WITNESS vHEREDF, said Grantor teas decree to set her hand and seat, the day and year first above written. Sealed and delivered in the pneseriae of. r EAL) t Linda K B Kbw # 3/ 3 i r i; e Doug 226 PAU 666 4-27-06; E:59hM;CDS LTK'r 7172624351 ? A- ? ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA: :ss COUNTY OF CUMBERLAND on Uft the, ft of '. y 2m. before we, a PUW. the undaaoned afiAr:er, persor>aNy &Mh K. wrrman, known to no or satis<actoruy prwve to the be person mftaftd to the *"* tnstruaerrR, and adkrMMedged that _ 1p same fm- ft purpose therein cwftkw f. •' •`.? IN WI17MMS W%MOF, I he Wf tD set my harrd and ? `. a...wr"01'eiji1ir,¦,,,?y,?, ?••Ct<.rr.-w-a,>aer mm" Pubk J - My Omvnission Exphes: I N "w c?rtlfy thaa ttre predse rest mm of the is m mom: rl ? OL"-kea W o,-' AA j,"W '- Attu q , cr Agdit for ca cir, Awl za f. BRUCE BARCLAY CHAIRMAN GARY EICHELBERGER VICE CHAIRMAN F JOHN BYRNE CHIEF OPERATIONS OFFICER EDWARD SCHORPP SOLICITOR RICHARD ROVEGNO TAX CLAIM BUREAU OF CUMBERLAND COUNTY STEPHEN D. TILEY SECRETARY ASSISTANT SOLICITOR One Courthouse Square, Carlisle, PA 17013-3389 Printed: 8/11/06 C (717) 240-6366 Receipt No.: 51107 15:18:26 Receipt Date: 8/11/2006 Control Number: 11-000314 **** RECEIPT **** Page: 1 Property Description: CRAIG, STEWART P & COLLEN RAE 85 OLD SAWMILL DRIVE NEWBURG PA 17240 Map No: 11-07-0495-016A LOT 1 PB 41 PG 87 Mobile Home - With Land Situs Information: 85 OLD SAWMILL DRIVE HOPEWELL TOWNSHIP Tax Penalty & Year Description Face Interest Costs Total 2004 CTY-HOPEWELL TWP 90.07 21.93 112.00 2004 CLB-HOPEWELL TWP 8.51 1.99 10.50 2004 SCH-SHIPPENSBURG 505.02 122.51 15.00 627.53 2004 BUREAU COSTS 101.70 101.70 Received For Year Of 2004 $866.73 Tendered > CHECK Received By > LM Paid By > HANNAH F. HERMAN SNYDER Remarks > 1559 Total Received $866.73 Balance Due As Of 8/11/2006 Claim Year: 2005 741.57 Claim Balance: 741.57 EXHIBIT a Receipt Number: 51107 Total Received: $866.73 COLLEEN R. CRAIG, Plaintiff/Petitioner V. STEWART P. CRAIG, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA : NO. 2002-1339 CIVIL ACTION-LAW IN DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the nth day of January, 2007, cause a true and correct copy of Plaintiffs Petition for Special Relief: Force of Sale of Marital Real Estate to be served upon Defendant by first-class mail, postage prepaid at the following address: DATE: l _ i Ia Stewart P. Craig 85 Old Sawmill Road Newburg, PA 17240 Hannah Herman-Snyder, Es' uire Attorney for Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE:.' ZC _ OLLEEN R. ICS , SAN 17 2007 0 COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant/Respondent IN DIVORCE ORDER OF COURT AND RULE TO SHOW CAUSE AND NOW this /9 r day of , 2007, upon presentation and consideration of the within Petition, it is hereby ORD D and DECREED that: 1. A Rule is hereby issued upon the Defendant/Respondent, Stewart P. Craig, to show cause, if any he has, as to why Plaintiff/Petitioner, Colleen R. Craig, is not entitled to the relief requested; 2. Defendant/Respondent shall file an Answer to Petition within twenty (20) days of service upon the Defendant/Respondent; 3. The Petition shall be decided under Pa.R.C.P. No. 206.7; 4. Depositions shall be completed within days of the service upon Plaintiff/Petitioner of the answer to the petition; 5. Hearing/Argument shall be held on , the day of , 2007, at J.m. in Courtroom # of the Cumberland County Courthouse, Carlisle, Pennsylvania; 6. If Items 4 and 5 above are left blank deposition and/or argument will be considered upon the request of any party; 7. Notice of entry of this Order shall be provided to all parties by Petitioner. L 1 :8 V 61 NVr LOOZ rtil?-I--/?? 1-? u,_.__. L.E_a r.... COLLEEN R. CRAIG, Plaintiff V. STEWART P. CRAIG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA : NO. 2002-1339 CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF SERVICE I confirm that I did this day of _ _'S? V /FA:--? , 2007, hand deliver a true and attested copy of a Petition for Special Relief. Force Sale of Marital Real Estate, filed on January 16, 2007, and the resulting Order of Court and Rule to Show Cause dated January 18, 2007, to Stewart P. Craig, at the following address: r(7 o Jam' JZS ,kQiv fir= Q Sworn and subscribed to before me this ?- day of dp,,u_aZ 2007. N (Constable) J 110TA LSM ow JIASSM NW"Pdk C/MUNFAX M. GOUN" w vuf*wpr11.3W f) C-il : Uzi . , w= alai ??Mfh?'° ?S?toN Ynxw MA-111U?' stilfF! 1tiC+JKT1: 4A tv"W3 COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant IN DIVORCE MOTION TO MAKE RULE ABSOLUTE AND NOW, comes Hannah Herman-Snyder, Esquire, and the law firm of Griffie & Associates and moves this Honorable Court as follows: 1. Movant is counsel for the above named Plaintiff, Colleen R. Craig. 2. Respondent is the above named Defendant, and adult individual currently residing at 85 Old Sawmill Road, Newburg, Cumberland County, Pennsylvania. 3. On January 16, 2007, Movant filed a Petition for Special Relief: Force Sale of Marital Real Estate. 4. A Rule to Show Cause was issued on January 18, 2007 by Judge Hess. 5. Service of the Petition for Special Relief. Force Sale of Marital Real Estate and the resulting Order of Court and Rule to Show Cause issued on January 18, 2007 was made by personal service on January 23, 2007. 6. An Affidavit of Service showing personal service of the Petition for Special Relief: Force Sale of Marital Real Estate and resulting Order of Court and Rule to Show Cause was filed on February 1, 2007, a copy of which is attached hereto and incorporated by reference as Exhibit "A". 7. As no response has been forthcoming from Defendant and no answer having been filed and twenty (20) days now having past, Movant requests your Honorable Court issue an Order granting the relief requested in the Petition for Special Relief: Force Sale of Marital Real Estate. WHEREFORE, Movant requests this Honorable Court grant Plaintiff permission, unilaterally, to sell the real estate at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania; sign all necessary documents associated with sale of the house on behalf of herself and the Defendant, Stewart P. Craig; and have undersigned counsel hold the proceeds until such time as the Divorce Master can hear the remainder of the parties' equitable distribution issues and distribute the proceeds accordingly. Respectfully Submitted, Hannah Herman-Snyder, E quire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 COLLEEN R. CRAIG, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. N0.2002-1339 C' STEWART P. CRAIG, CIVIL ACTION-LAW _, Defendant : IN DIVORCE AFFIDA VIT OF SERVICE 77 12 DI .1 14 A:) I confirm that I did this day of U , 2007, hand de river a true and attested copy of a Petition for Special Relief: Force Sale of Marital Real Estate, filed on January 16, 2007, and the resulting Order of Court and Rule to Show Cause dated January 18, 2007, to Stewart P. Craig, at the following address: o t/?'?Z S 'k'j[.C) f w/?? r (Constable) r Sworn and subscribed to before me this sue` *? day of dam ts, 2007. NOTARY? SM NOBINJBA8 M MAY CMLWq0RMW,CUWERLAWC0UW My Oon?INala?£+?aM? EXHIBIT COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the i5-_t1-,day of February, 2007, cause a true and correct copy of Plaintiff's Motion to Make Rule Absolute to be served upon Defendant by first-class mail, postage prepaid at the following address: Stewart P. Craig 85 Old Sawmill Road Newburg, PA 17240 DATE: a - v S - ?Cl Hannah Herman-Snyder, Esq ire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: HANNAH HERMAN-SNY R, ESQUIRE N G E O COLLEEN R. CRAIG, Plaintiff VS. STEWART P. CRAIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 1339 CIVIL IN DIVORCE NOTICE OF FILING OF MASTER'S REPORT The report of the Master has been filed this date and copies have been sent with this notice to counsel of record and the parties. In accordance with P.R.C.P. 1920.55 within ten (10) days after the mailing of this notice and report exceptions may be filed to the report by any party. If no exceptions are filed within the ten (10) day period, the Court shall receive the report, and if approved, shall enter a final decree in accordance with the recommendations contained in the report. SO". Date: 2/26/07 E. Robert Elicker, II Divorce Master NOTE: If exceptions are filed, file the original with the Prothonotary and a copy with the Master's office. At that time, the party filing the exceptions should notify the court reporter in the Master's office so arrangements can be made for a transcript. Upon completion of the transcript and receipt of payment, the entire file will be returned to the Prothonotary's office for transmittal to the Court at time of argument on the exceptions. If no exceptions are filed, counsel shall prepare an order of Court consistent with the recommendations and provide a proposed order of Court to the Master. Counsel shall also prepare and provide with the proposed order of Court a praecipe* to the i Prothonotary directing the Prothonotary to submit the case to the Court for final disposition. The Master will then transfer the file with the proposed order of Court and praecipe to the Prothonotary's Office for docketing and transmittal by the Prothonotary to the Court. * Form available in the Prothonotary's office and the Master's office. (NOT the praecipe to transmit the record form as set out in P.R.C.P. 1920.73(b).) C7-1 COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 02 - 1339 CIVIL STEWART P. CRAIG, Defendant IN DIVORCE MASTER'S REPORT AND TRANSCRIPT OF PROCEEDINGS Proceedings held before E. Robert Elicker, II, Divorce Master 9 North Hanover Street, Carlisle, PA 17013 proceedings held on February 22, 2007 commencing at 9:00 a.m. APPEARANCES: Hannah Herman-Snyder Attorney for Plaintiff Stewart P. Craig (did not appear) Defendant COLLEEN R. CRAIG, Plaintiff VS. STEWART P. CRAIG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 1339 CIVIL IN DIVORCE THE MASTER: Today is Thursday, February 22, 2007. This is the date set for a hearing in the above-captioned divorce proceedings. Present in hearing room are the Plaintiff, Colleen R. Craig, and her counsel Hannah Herman-Snyder. Stewart P. Craig has not appeared nor has any counsel contacted the Master's office indicating that he or she was going to be representing Mr. Craig. An order and notice of hearing dated January 2, 2007, was sent by first-class mail through the United States Postal Service to Mr. Craig at 85 Old Sawmill Lane, Newburg, Pennsylvania. The Master's office has not had the notice returned by the postal service indicating that the addressee is unknown or that the addressee refused to accept the mailing from the Master's office. Therefore, we are going to proceed on the basis that Mr. Craig did receive notice of today's hearing. It is further noted, however, that consistent with Mr. Craig not being present today, he has not participated nor appeared in any matters involving litigation in this case or conferences or meetings that have been previously scheduled. Consequently, Mr. Craig's non-appearance today is consistent 1 with his lack of participation in this case from the beginning. This action was commenced by the filing of a complaint in divorce on March 19, 2002, raising grounds for divorce of irretrievable breakdown of the marriage. The Plaintiff filed an affidavit under Section 3301(d) of the Domestic Relations Code dated September 24, 2003, averring that the parties separated on August 11, 2002, a period of a least two years. Along with the affidavit was a counter-affidavit which Mr. Craig has not returned or filed. Therefore, the divorce can conclude under Section 3301(d) of the Domestic Relations Code. The complaint also raised the economic claim of equitable distribution. The Plaintiff filed an additional claim for economic relief by petition on September 11, 2006, asking for counsel fees and costs. No claim has been raised by either party for alimony. The parties were married on February 14, 1997, and separated August 11, 2002. They are the natural parents of one child, Rayna Craig, born May 16, 1996, who is in the custody of wife. The Master was appointed in these proceedings on September 14, 2006. 2 We are going to take the testimony of Mrs. Craig which will be presented through her statement on the record as well as a set of documents which has been prepared by her attorney and Mrs. Craig, which will be made part of the record and part of the Master's report. It is noted that the wife filed a petition on January 16, 2007, with the Court requesting that the Court enter an order forcing the sale of the marital real estate at 85 Old Sawmill Lane, Newburg, Pennsylvania. Mr. Craig did not respond to that petition and wife's counsel has asked that the rule to show cause to sell the real estate be made absolute. Wife's counsel has presented an order to the Honorable Kevin A. Hess to have the rule made absolute providing that the real estate be sold. The order that attorney Herman-Snyder presented is made a part of these proceedings. It is not known at this time whether Judge Hess has signed the order but it is anticipated that the order will be signed if it has not already been done so. Therefore, we are going to proceed on the basis that there will be an order directing that the real estate at 85 Old Sawmill Lane, Newburg, Pennsylvania, be sold. Wife's address is 260 Airport Road, Shippensburg, Pennsylvania. The Master is going to have the witness sworn and then attorney Herman-Snyder can proceed with her 3 examination and presentation of testimony and exhibits. We do not anticipate any other witnesses. The time is 9:18 a.m. and Mr. Craig has not appeared. Whereupon, COLLEEN R. CRAIG, having been duly sworn, testified as follows: DIRECT EXAMINATION BY MS. HERMAN-SNYDER: Q Would you state your name and address for the record. A Colleen R. Craig, 260 Airport Road, Shippensburg, Pennsylvania. Q Did we prepare a statement for today in preparation for the Master's hearing that dealt with all of your assets and debts? A Yes. (Whereupon, Plaintiff's Exhibit No. 1 was marked for identification.) BY MS. HERMAN-SNYDER: Q I'm going to show you what has been marked Plaintiff's No. 1 and this is the statement that we have prepared together, correct? A Yes. Q I'm going to show you the verification page, is that your signature on the verification stating that everything in here is true and correct? 4 A Yes. (A discussion was held off the record.) THE MASTER: As part of the exhibit, wife has suggested recommendations with regard to the disposition of the assets and the debts. The Master, after discussion with attorney Herman-Snyder, has indicated that the Master will make further additions to the recommendations as part of his report. Those recommendations as stated on Page 3 and Page 4 of wife's statement and exhibit provide as follows: Paragraph one provides for the sale of the marital real estate in accordance with an order by Judge Hess which we anticipate will be signed subsequent hereto. Paragraph two provides for the distribution of the proceeds from the sale of the marital real estate and specifically sets forth in the subparagraphs how those proceeds are to be distributed. Paragraph three provides that wife shall retain her defined contribution plans through her employer. Specifically those plans should be identified as the Ingersoll-Rand Company employee savings plan and the Ingersoll-Rand Clark Leveraged employee stock ownership plan. MASTER'S REPORT 5 The statement on the record by the Master prior to the testimony of wife and presentation of her exhibit is adopted as part of the Master's report as a summary of the proceedings. GROUNDS FOR DIVORCE An affidavit under Section 3301(d) was filed on September 24, 2003, and no counter-affidavit having been filed thereto raising any objections to the affidavit, and the parties having been separated for a period in excess of two years, wife is entitled to a divorce under Section 3301(d) of the Domestic Relations Code. RECOMMNDATIONS 1. The marital real estate shall be sold in accordance with an order of Judge Hess which has been signed or will be signed subsequent hereto. 2. The proceeds from the marital real estate, land only, shall be distributed such that wife shall receive 500 of the net proceeds, as should husband. However, wife shall be given the following from husband's portion prior to any distribution to him: a. Reimbursement for the taxes she paid on behalf of Mr. Craig, in the amounts of $866.73 and $733.00; b. Reimbursement for 1/2 of the marital debt wife paid to IRCO (1/2 of $4,079.57) - $2,039.79; C. Reimbursement for any real estate taxes due at the time of settlement and deducted as routine settlement costs; d. One-half of the rental value for the sixty-six (66) months Mr. Craig had sole use and possession of the 6 marital real estate and trailer in the amount of $500.00/month (1/2 of $33,000.00) - $16,500.00; e. Attorney fees and costs in the amount of $4,462.50; f. Reimbursement for half of the debt due and owing to Debt Recovery Solutions, LLC on behalf of Sprint, in regards to the telephone bill (1/2 of $807.98) - $403.00. Wife shall be responsible for paying said bill, and shall be reimbursed as stated. However, if the amount has increased any more than $20.00, husband shall reimburse her for half of any amount over the $20.00 increase; 9. Reimbursement for half of the debt due and owing to Troon Company Partners LLC in regards to the Chevy Cavalier (1/2 of $1,283.56) - $641.78. However, if the amount has increased any more than $20.00, husband shall reimburse her for half of any amount over the $20.00 increase; and h. Reimbursement for 1/2 the value of the parties' trailer (1/2 of $1,000.00) - $500.00. Wife shall sign over the title of the parties' trailer upon being requested by Mr. Craig to do so. 3. Wife shall retain her defined contribution plans through her employer. Specifically those plans are identified as the Ingersoll-Rand Company employee savings plan and the Ingersoll-Rand Clark Leveraged employee stock ownership plan. 4. The Master recommends that husband remove the trailer at 85 Old Sawmill Lane, Newburg, Pennsylvania, within thirty (30) days of a final order in these proceedings as well as vacating the premises physically himself so that the trailer is no longer on the real estate and husband is no longer living in the trailer located on the real estate. The purpose of this recommendation is to give wife a more reasonable opportunity to sell the real estate without any interference from husband on the premises. The sale of the premises and the details thereto will be outlined and will be handled as provided in Judge Hess' order which will indicate wife's authority to proceed with the disposition of this property. 5. It is further noted that the provisions in the recommendations in the subparagraphs in Paragraph two above shall not be able to be implemented until such time as the real estate proceeds have been identified and escrowed. 7 Wife is willing to forego any claims that are not able to be paid out of the proceeds from the sale of the real estate. Respectfully submitted, E. Robert Elicker, II Divorce Master 8 f ? ? ' Gl ,? t` j W„e? _ ? i ' ?t _ t -'J ?'[? .?. t. ? ? - FEB ie zom,0 ? COLLEEN R. CRAIG, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.2002-133 9 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant IN DIVORCE ORDER OF COURT AND NOW this .23 `4 day of 2007, upon presentation and consideration of the within Motion to Make Rule Absolute, it is hereby ORDERED AND DECREED that Plaintiff, Colleen R. Craig, is hereby granted the power, unilaterally, to sell the real estate located at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania, and sign all necessary documents associated with sale of the house on behalf of herself and the Defendant, Stewart P. Craig. All proceeds from that sale of said residence shall be held by undersigned counsel until such time as the Divorce Master can hear the parties' remaining equitable distribution issues and distribute the proceeds accordingly. By the Court, J. '? ?? ^? 9.,? 4? v ? ` .,? 5 s ? ?} ? ??z? ?? G? ??, "1`, jt.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Colleen R. Craig vs. Stewart P. Craig It appearing th been filed for ten (10 that the costs have h and Rules of Court h said case to the Couj Pennsylvania, at the TO: Curtis Long Prot: DATED: ) y - 1, -( "(W5 A Common Pleas of that the costs in t Master's fee. Plaintiff No. 02-1339 Defendant Civil 20 02 Lt the Master's report in the above stated case has days, that no exceptions have been filed thereto, en fully paid and that all the requirements of law .ve been met, you are hereby directed to submit the of Common Pleas of Cumberland County, text sitting thereof. Attorney for Plaintiff ?bA)(9 , Prothonotary of the Court of mberland County, Pennsylvania, do hereby certify above stated case, have all been paid, including the t on ary COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 2002-1339 STEWART P. CRAIG, Defendant :CIVIL ACTION LAW IN DIVORCE ORDER OF COURT AND NOW this Z4 day of --v- , 2007 as no exceptions to the Master's Report, filed February 26, 2007, have been filed, it is hereby ORDERED and DIRECTED that the Master's Report and Recommendation are adopted. IT IS FURTHER ORDERED that: 1. The marital real estate located 8l of as Sawmill forth in the Honorable Kevin County, Pennsylvania, shall be disposed Hess's Order of Court, dated February 23, 2007. 2. The proceeds from the marital real estate, land only, shall be distributed such that upon the sale of said real estate, Wife shall receive 50% of the net proceeds, as should Husband. However, Wife shall be reimbursed the following from Husband's portion prior to any distribution to him: a. Reimbursement for the taxes Wife paid on behalf of Husband, in the amount $866.73 and $733.00; b. Reimbursement for one half of the marital debt Wife paid to IRCO (1/2 of $4,079.57) - $2,039.79; C. Reimbursement for any real estate taxes due at the time of settlement and deducted as routine settlement costs; d. One-half of the rental value for the sixty-six (66) months Husband had sole use and possession of the marital real estate and trailer in the amount of $500.00/month (1/2 of $33,000.00) - $16,500.00; e. Attorney fees and costs in the amount of $4,462.50; f. Reimbursement for one half of the debt due and owing to Debt Recovery Solutions, LLC on behalf of Sprint, in regards to the telephone bill (1/2 of $807.98) - $403.00. Wife shall be responsible for paying said bill, and shall be reimbursed as stated. shall reimburse her for one half of any amount more than $20.00, Hu over the $20.00 increase; g. Reimbursement for one half of the debt due and owing to Troon Company Partners, LLC in regards to the Chevy Cavalier (1/2 of $1,283.56) $641.78. However, if the amount has increased any more than $20.00, Husband shall reimburse Wife for one half of any amount over the $20.00 increase; and h. Reimbursement for one half of the value of the parties' trailer (1/2 of $1,000.00) - $500.00. Wife shall sign over the title of the parties' trailer upon being requested by Husband to do so. 3. Wife shall retain her defined contribution plans through her employer. loyee and Ingersoll-Rand Specifically said plans are identified Leveraged Company Employee pStock Savings Plan and the Ingersoll-Rand Ownership Plan. 4. Husband shall remove the trailer at 85 Old Sawmill Lane, Newburg, Pennsylvania within thirty (30) days of a final Order in these proceedings, as well as vacating the premises physically himself so that the trailer is no longer on the real estate and Husband is no longer living in the trailer located on the real estate. The sale of the real estate shall take place according to the Honorable Kevin J. Hess's Order of Court, dated February 23, 2007, which indicates Wife's authority to proceed with the disposition of said property. 5. The distribution as set forth in have been identified andl not tae place until such escrowed. time as the real estate proceeds 6. Wife shall forego any and all from as set fo in Paragraph two the sale of the real estat p (2)' that are not able to be paid out of the p By the Court, P/C- "P-r °p,? ray 81 .1 141 go em 100Z L ?? ? i0 1 C f ?Hi 20 3,,,Iv-,c)--n5-7u THE COURT OF COMMON PLEAS IN OF CUMBERLAND COUNTY Aft STATE OF PENNA. Colleen R. Craig, II No. 2002-1339 Plaintiff VERSUS Stewart P. Craig, Defendant DECREE IN DIVORCE 1J-(,4 j , IT IS ORDERED AND AND NOW, Colleen R. Craig , PLAINTIFF, DECREED THAT DEFENDANT, AND Stewart P. Craig ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE R WHICH AI CLAIMS NOT BEEN RAISED OF RECORD IN THIS ACTION FOR YET BEEN ENTERED; Al6 Pf b2- 4V. e COLLEEN R. CRAIG, Plaintiff/Petitioner V. STEWART P. CRAIG, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 2002-1339 THE HONORABLE KEVIN A. HESS IN DIVORCE PETITION FOR ENFORCEMENT OF MARCH 26, 2007 ORDER OF COURT AND NOW, comes Petitioner, Colleen R. Craig, by and through her attorney of record Hannah Herman-Snyder, Esquire, and the law firm of Griffie & Associates and petitions this Honorable Court as follows: 1. Petitioner is the above named Plaintiff, an adult individual currently residing at 260 Airport Road, Shippensburg, Cumberland County, Pennsylvania. 2. Respondent is the above named Defendant, an adult individual currently residing at 85 Old Sawmill Road, Newburg, Cumberland County, Pennsylvania. 3. The parties, having been married, were granted their divorce on March 26, 2007. 4. Petitioner obtained a 3301(d) divorce and equitable distribution, pursuant to a Report and Recommendation of the Divorce Master, having been made an Order of Court on March 26, 2007, a copy of which is attached and incorporated herein by reference as Exhibit "A". 5. A true and attested copy of the Order of Court dated March 26, 2007 was send to Respondent on April 3, 2007 by counsel for Petitioner. 6. Respondent did not participate in the divorce proceedings in any matter, not having submitted any documents or shown for any conferences or hearings. 7. The Order of Court entered on March 26, 2007 states that "the marital real estate located at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania, shall be disposed of as set forth in the Honorable Kevin J. Hess's Order of Court dated February 23, 2007, a copy of said Order is attached and incorporated herein by reference as Exhibit "B". 8. A true and attested copy of the Order of Court dated February 23, 2007 was sent to Respondent on March 2, 2007 by counsel for Petitioner. 9. The Order of February 23, 2007 grants Petitioner the unilateral power to sell the real estate located at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania, and sign all necessary documents associated with the sale of the house on behalf of herself and the Respondent. 10. Also, pursuant to the Order of March 26, 2007, Respondent was to remove the trailer at 85 Old Sawmill Lane, Newburg, Pennsylvania within thirty (30) days of a final Order, as well as vacating the premises physically himself so that the real estate could be sold. 11. As of today's date, Respondent has not removed himself, or the trailer from said premises. 12. Petitioner is currently working with a real estate agent to sell the real estate at issue and there has been an offer on the real estate. 13. As Respondent has taken no part in the divorce proceedings, Petitioner believes and therefore avers that it is necessary to have Respondent forcibly removed from the premises in order to sell the real estate at 85 Old Sawmill Lane, Newburg, Pennsylvania. 14. Petitioner believes and therefore avers that Husband will make no effort to remove the trailer from said residence and as such she may be required to dispose of said trailer and/or sign over the title of the parties' trailer to a third parry. 15. Said Order allows that in conjunction with the entire Order, Petitioner shall, after appropriate payment, sign over the title of the trailer to Respondent, upon his request. 16. Pursuant to local rule 208.3(a)(9), a copy of the Petition has been provided to Respondent, who has not been represent throughout the proceedings. 17. Pursuant to the requirements of local rule 208.3(a)(2), it is noted that the Honorable Kevin A. Hess ruled previously in this matter, in that he issued the Order on Petitioner's Motion to Make Rule Absolute, and he issued the Order adopting the Master's Report and Recommendations. WHEREFORE, Petitioner requests this Honorable Court order the following: a. Respondent shall be forcibly removed from the residence at 85 Old Sawmill Lane, Newburg, Pennsylvania by the Cumberland County Sheriff s Office. b. Respondent shall either remove the trailer at 85 Old Sawmill Lane, Newburg, Pennsylvania within fifteen (15) days of the date of this Order, or Petitioner shall be entitled to sell the trailer and retain all proceeds. Furthermore, Petitioner is hereby granted the power, unilaterally to sign all necessary documents associated with the sale of the trailer on behalf of both herself and Respondent if it is not removed within fifteen (15) days of the date of this Order. C. Petitioner shall be awarded attorney's fees in the amount of $500.00, which shall be payable from Respondent's portion of the net proceeds from the sale of the marital real estate. Respectfully Submitted, Hannah Herman-Snyder, squire Attorney for Petitioner GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: S o /IjIt- .1 (zi? LLEEN G J COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2002-1339 STEWART P. CRAIG, Defendant CIVIL ACTION LAW IN DIVORCE ORDER OF COURT AND NOW this ZG ' day of 2007 as no exceptions to the Master's Report, filed February 26, 2007, have been filed, it is hereby ORDERED and DIRECTED that the Master's Report and Recommendation are adopted. IT IS FURTHER ORDERED that: 1. The marital real estate located at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania, shall be disposed of as set forth in the Honorable Kevin J. Hess's Order of Court, dated February 23, 2007. 2. The proceeds from the marital real estate, land only, shall be distributed such that upon the sale of said real estate, Wife shall receive 50% of the net proceeds, as should Husband. However, Wife shall be reimbursed the following from Husband's portion prior to any distribution to him: a. _Reimbursement for the taxes Wife paid on behalf of Husband, in the amount $866.73 and $733.00; b. Reimbursement for one half of the marital debt Wife paid to IRCO (1/2 of $4,079.57) - $2,039.79; C. Reimbursement for any real estate taxes due at the time of settlement and deducted as routine settlement costs; d. One-half of the rental value for the sixty-six (66) months Husband had sole use and possession of the marital real estate and trailer in the amount of $500.00/month (1/2 of $33,000.00) - $16,500.00; e. Attorney fees and costs in the amount of $4,462.50; EXHIBIT A f. Reimbursement for one half of the debt due and owing to Debt Recovery Solutions, LLC on behalf of Sprint, in regards to the telephone bill (1/2 of $807.98) - $403.00. Wife shall be responsible for paying said bill, and shall be reimbursed as stated. However, if the amount has increased any more than $20.00, Husband shall reimburse her for one half of any amount over the $20.00 increase; g. Reimbursement for one half of the debt due and owing to Troon Company Partners, LLC in regards to the Chevy Cavalier (1/2 of $1,283.56) $641.78. However, if the amount has increased any more than $20.00, Husband shall reimburse Wife for one half of any amount over the $20.00 increase; and h. Reimbursement for one half of the value of the parties' trailer (1/2 of $1,000.00) - $500.00. Wife shall sign over the title of the parties' trailer upon being requested by Husband to do so. 3. Wife shall retain her defined contribution plans through her employer. Specifically said plans are identified as the Ingersoll-Rand Company Employee Savings Plan and the Ingersoll-Rand Clark Leveraged Employee Stock Ownership Plan. 4. Husband shall remove the trailer at 85 Old Sawmill Lane, Newburg, Pennsylvania within thirty (30) days of a final Order in these proceedings, as well as vacating the premises physically himself so that the trailer is no longer on the real estate and Husband is no longer living in the trailer located on the real estate. The sale of the real estate shall take place according to the Honorable Kevin J. Hess's Order of Court, dated February 23, 2007, which indicates Wife's authority to proceed with the disposition of said property. 5. The distribution as set forth in Paragraph two (2) shall not take place until such time as the real estate proceeds have been identified and escrowed. 6. Wife shall forego any and all claims, as set forth in Paragraph two (2), that are not able to be paid out of the proceeds from the sale of the real estate. By the Court, J. TRUE COPY FROM RECORD in Testimony why reryf, 1 =t r s unto set my hand and the seal of sai! ; at Carlisle, Pa. This .....:a?4e..... day of....lj!t u ..., ? Prothonotary FEB J ? 2Q07 COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant IN DIVORCE ORDER OF COURT 1D IOW thzs day of 2007, upon presentation and consi mat :on -,Qf _ the within Motion to Make Rule Absolute, it is hereby ORDERED AND f .. DECREE that Plaintiff,?'o?ll""eerie Craig, is hereby granted the power, unilaterally, to sell the real estate located at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania, and sign all necessary documents associated with sale of the house on behalf of herself and the Defendant, Stewart P. Craig. All proceeds from that sale of said residence shall be held by undersigned counsel until such time as the Divorce Master can hear the parties' remaining equitable distribution issues and distribute the proceeds accordingly. By the Court, J. E EXHIBIT o Tsdffay wherein, I here unto set my hanc lad the seal of said C at at Cafte, Pa. 3 lay of j Pmftnotars COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant IN DIVORCE ORDER OF COURT AND NOW this day of , 2007, upon presentation and consideration of the within Motion to Make Rule Absolute, it is hereby ORDERED AND DECREED that Plaintiff, Colleen R. Craig, is hereby granted the power, unilaterally, to sell the real estate located at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania, and sign all necessary documents associated with sale of the house on behalf of herself and the Defendant, Stewart P. Craig. All proceeds from that sale of said residence shall be held by undersigned counsel until such time as the Divorce Master can hear the parties' remaining equitable distribution issues and distribute the proceeds accordingly. By the Court, J. COLLEEN R. CRAIG, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant : IN DIVORCE -'? MOTION TO MAKE RULE ABSOLUTE" AND NOW, comes Hannah Herman-Snyder, Esquire, and the law firm of 6r"e Associates and moves this Honorable Court as follows: 1. Movant is counsel for the above named Plaintiff, Colleen R. Craig. 2. Respondent is the above named Defendant, and adult individual currently residing at 85 Old Sawmill Road, Newburg, Cumberland County, Pennsylvania. 3. On January 16, 2007, Movant filed a Petition for Special Relief. Force Sale of Marital Real Estate. 4. A Rule to Show Cause was issued on January 18, 2007 by Judge Hess. 5. Service of the Petition for Special Relief. Force Sale of Marital Real Estate and the resulting Order of Court and Rule to Show Cause issued on January 18, 2007 was made by personal service on January 23, 2007. 6. An Affidavit of Service showing personal service of the Petition for Special Relief: Force Sale of Marital Real Estate and resulting Order of Court and Rule to Show Cause was filed on February 1, 2007, a copy of which is attached hereto and incorporated by reference as Exhibit "A". 7. As no response has been forthcoming from Defendant and no answer having been filed and twenty (20) days now having past, Movant requests your Honorable Court issue an Order granting the relief requested in the Petition for Special Relief. Force Sale of Marital Real Estate. 'VNT EREFORE, Movant requests this Honorable Court grant Plaintiff permission, unilaterally, to sell the real estate at 85 Old Sawmill Lane, Newburg, Cumberland County, Pennsylvania; sign all necessary documents associated with sale of the house on behalf of herself and the Defendant, Stewart P. Craig; and have undersigned counsel hold the proceeds until such time as the Divorce Master can hear the remainder of the parties' equitable distribution issues and distribute the proceeds accordingly. Respectfully Submitted, Hannah Herman-Snyder, E quire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 COLLEEN R. CRAIG, : IN TIE COURT OF COMMON PLEAS Plaintiff : CUA4BERLAND COUNTY PENNSYLVANIA. N0.2002-1339 7n STEWART P. CRAIG, CIVIL ACTION-LAW Defendant : IN DIVORCE M ;. -'7 _? ., . T; AFFIDANrIT OF SERN71CE -- - ?, I-r' 112 DI I confirm that I did this Z day of U Lk- ? 2007, hand deliver a true and attested copy of a Petition for Special Relief: Force .`Sale of Marital Real Estate, filed on January 16, 2007, and the resulting Order of Court and Rule to Show Cause dated January 18, 2007, to Stewart P. Craig, at the following address: r T- v - 0 '. vi.v ? r J (Constable) Sworn and subscribed to before me this Aye day of _.?t? - , 2007. N }rpm"LSEAL R091N J BASSETT wowy puw ?,1SL1:$pRDUGH, s;:1N?ERlAND?NTi' My i3orem1?rlon ?xprK ? 17,3007 EXHIBIT COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the I5-i ? day of February, 2007, cause a true and correct copy of Plaintiffs Motion to Make Rule Absolute to be served upon Defendant by first-class mail, postage prepaid at the following address: Stewart P. Craig 85 Old Sawmill Road Newburg, PA 17240 DATE: a - 15 -j-1 Hannah Herman-Snyder, Esq ire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 • VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE: ?- i c -01 HANNAH HERMAN-SN R, ESQUIRE COLLEEN R. CRAIG, Plaintiff/Petitioner V. STEWART P. CRAIG, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA : NO. 2002-1339 : THE HONORABLE KEVIN A. HESS : IN DIVORCE CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the j't day of May, 2007, cause a copy of Plaintiff's Petition for Enforcement of March 26, 2007 Order of Court to be served upon Defendant by first-class mail, postage prepaid at the following address: Stewart P. Craig 85 Old Sawmill Road Newburg, PA 17240 DATE: ?? T1 Hannah Herman-Snyder, Esq re Attorney for Petitioner GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 CID - ct' ? COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NO. 02-1339 CIVIL STEWART P. CRAIG, Defendant/Respondent IN DIVORCE IN RE: PETITION TO ENFORCE ORDER AND NOW, this 22') day of May, 2007, a brief hearing in the above-captioned matter is set for Wednesday, May 30, 2007, at 11:00 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. BY THE COURT, .4 Hess, J. /annah Herman-Snyder, Esquire For the Plaintiff/Petitioner tewart P. Craig, Pro Se . Defendant/Respondent :rlm U U, i 3 Ar- COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW STEWART P. CRAIG, NO. 02-1339 CIVIL TERM Defendant/Respondent IN DIVORCE IN RE: PETITION FOR ENFORCEMENT OF MARCH 26, 2007, ORDER ORDER OF COURT AND NOW, this 30th day of May, 2007, this matter having been called for hearing, it appearing that the respondent has not removed himself from the residence at 85 Old Sawmill Lane, Newburg, Pennsylvania, and is therefore in violation of our order of court dated March 26, 2007, a rule is issued upon the respondent to show cause why he should not be cited in contempt. This rule returnable and to be heard in Courtroom No. 4 of the Cumberland County Courthouse on Wednesday, June 6, 2007, at 11:30 a.m. The respondent is ordered and directed to remove the trailer at 85 Old Sawmill-Lane, Newburg, Pennsylvania, within fifteen days of the date of this order. In default thereof, the petitioner shall be entitled to sell the trailer and retain all proceeds following further motion to the court. Furthermore, the petitioner will be granted the power unilaterally to sign all necessary documents associated with the sale of the trailer on behalf of both herself and respondent if it is not removed within fifteen days of the date of this order. The petitioner is herewith awarded additional attorney's fees in the amount of $500.00, which shall be payable from respondent's portion of the net proceeds from the sale of the marital real estate. VINVA` ASNN3d BE :Z Wd a£ AVW LOOZ KdViONOr i0 d 3Hi 3© 3OL4.10- 1311 NO. 02-1339 CIVIL TERM By the Court, - -" (" , " /, " g'l' Kevi A. Hess, J ?nannah Herman-Snyder, Esquire For the Plaintiff/Petitioner tewart P. Craig 85 Old Sawmill Lane , Newburg, PA Defendant/Respondent bg A COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE I confirm that I did this day of 'l/ , 2007, hand deliver a true copy of Plaintiff's Petition for Enforcement of March 26, 2007 Order of Court and a true and attested copy of the resulting Order of Court, dated May 22, 2007, scheduling a hearing for Wednesday, May 30, 2007 at 11:00 a.m. to Stewart P. Craig, at the following address: C_o vc5 U_- A U`c v Sworn and subscribed to before m this day of? , 2007. N "07"M am wary ft *ft U Apt 17, got 1 c C= -n . M , xo -< ? -n ce ?• J I q!! A 1 W44 HligX3 noolo aso* COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2002-1339 STEWART P. CRAIG, CIVIL ACTION-LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE I confirm that I did this day of , 2007, hand deliver a true copy of the Order of Court, dated May 30, 2007, issuing a Rule to Show Cause and scheduling a hearing for Wednesday, June 6, 2007 at 11:30 a.m. in Courtroom No. 4 of the Cumberland County Courthouse to Stewart P. Craig, at the following address: Ub A070 L ' Sworn and subscribed to before me this jl 2007. Noun SIM ROHN J. SAIISM NO" Public ? MV C0111111 01110M INVhOS Apt 17, 2011 1 C -n y.. ?? f rolt`,t? . f , ?ESti a,??i?5 r ? ;w COLLEEN R. CRAIG, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V CIVIL ACTION - LAW STEWART P. CRAIG, NO. 02-1339 CIVIL TERM Defendant/Respondent IN DIVORCE IN RE: PETITION FOR CONTEMPT OF COURT ORDER OF COURT AND NOW, this 6th day of June, 2007, action on the pending contempt citation is deferred in accordance with the agreement of the parties as announced this date in open court and in their presence. If this matter is not relisted for hearing within sixty days, the pending contempt citation will be deemed dismissed without further order of court. By the Court, evin/A. Hess, J. /radley Griffie, Esquire For the Plaintiff/Petitioner wart P. Craig 85 Old Sawmill Lane Newburg, PA Defendant/Respondent : bg iti ii - no