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Home My WebLink About06-1380AUG 02200 GREGORY MILLIGAN : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO: 06-1380 TERESA MILLIGAN : CIVIL ACTION -LAW DEFENDANT : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER GREGORY MILLIGAN, Plaintiff, moves the Court to appoint a Master with respect to the following claims: [ x ] Divorce [ x ] Distribution of Property [ ] Annulment [ ] Support [ ] Alimony [ ] Counsel Fees [ ] Alimony Pendent Lite [ ] Costs and Expenses and in support of the Motion the Plaintiff states: 1. Discovery is complete as to the claim for which the appointment of a Master is requested. 2. The Defendant has appeared in the action personally. 3. The statutory ground for the divorce is: §§ 3301(c). 4. The action is contested with respect to the following claims: Distribution of Property 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 motions: DATE ?Q I 1A A-4.0 Michelle L. So er, Esquire Attorney for Plaintiff AND NOW, this day of , 2007, Esquire is - ? appointed Master with respect to the/following claims: BY COU , n.v I rw AL J• 5 c") Q `3 0- t CV Q Q ? U W? r r A A f p{?r sv -57 °f - co ?' rv) GREGORY MILLIGAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA 64 -13P V. NO. CIVIL TERM TERESA MILLIGAN, Defendant CIVIL ACTION - LAW 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 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, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 GREGORY MILLIGAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 064 3 80CIVIL TERM TERESA MILLIGAN, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT 1. Plaintiff is Gregory Milligan, who currently resides at 1419 N. 2nd Street, #305, Harrisburg, Dauphin County, Pennsylvania 17102. 2. Defendant is Teresa Milligan, who currently resides at 5857 Vaughn Road, East Petersburg, Lancaster County, Pennsylvania 17520. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 3, 1995 at VillaNova, Montgomery County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, 5 3301(c), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since June 18, 2004 and continue to do so. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from July 3, 1995, until June 18, 2004, the date of their separation, which property is "marital property". 12. Plaintiff and Defendant may have owned, prior to marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property" 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, the Plaintiff requests this Honorable Court to equitably divide all marital property. DATE 03 V Respectfully submitted, AsoM& KUTULAKUS, L.L.P. d,?j2r?%WtJ. Kara W. Haggerty 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ID No. 86914 VERIFICATION I, GREGORY MULLIGAN, verify that the statements made in this Divorce Complaint 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.GS. § 4904 relating to unworn falsification to authorities. Date \ ?'} ?' '? N v, ? V^, -,? ?? i7 t ??1 _ ?? ,. ?. :'1 G' ? ? ._ , ?h C; IF '4% GREGORY MILLIGAN, Plaintiff v. TERESA MILLIGAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-1380 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Kathleen A. Engle, hereby certify that I did serve a true and correct copy of the Complaint under Section 3301(c) and 3301(d) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on June 14, 2006, at Carlisle, Pennsylvania, addressed as follows: Teresa Milligan 5857 Vaughn Road East Petersburg, PA 17520 Return card acknowledging receipt on June 15, 2006, is attached as Exhibit "A>, ABOM & KUTULAMS,, LLP Date:?7, 62 '4.'CK=c ? Kathleen A. Engle, Esquire 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 200616 f - On' i CERTIFIED MAIL... R ECEIPT o (Domestic Mail Only; No Insuranc e Coverage Provided) .A OFFICIA L USE M Ln postage e v Ce tlead Fes CID S(p' !?" DrP C3 0 (EnOq M M S poem e e Here Q a Reetrktec Delivery Fee (Fade Bement R.yal eo) - b b(? M Total postage d Fees $ • i?78 M °o Q {rF S0. ( l a 1?. r' ------ 3Yiiel' CWC ----- --- ? ? 1 orpo?,t. 5 --------- ---w ------ ri Uaal -.-X-- ----•--- ............ npw74 -------------- --------------- ¦ Complete Items 1.2. and 3. Also corrpWW Item 4 N Restricted DWvery is deeked. ¦ Print yaw two and address on the reveres so VW we can mtum the card to you. ¦ Attach this cad to the back of the malipieoe, or on the front it apace permits. 1. Mole Addased to: TrfsoL Nlllll^AM S 35 ? vGL?LJn Qff . Eas?- PA ? ?5 ao 2. Mice Number (nan ter horn aerwoebw A. ?? X oAddestese B. d by( my C. Ode V -6_( - O. te ttern 1? ? Yee N YES. emer rjeevery b elow. pNo 1 a am ?w 0 Registered .1 19 p t for MweheMhe 0 IrwxwMss 4. Restricted DaiNery7 pit go 0 Yee 7003 3110 0004 5768 4054 PS Forth 3811. FeWuary 2004 Dorneetb Return Receipt r ? .? ?-i'? ??? .,..? ?; J,^? ? ? " ? C :: ? ?? ..1 GREGORY MILLIGAN, Plaintiff V. TERESA MILLIGAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-1380 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ENTRY OF APPEARANCE Please enter the appearance of the undersigned as counsel for the Plaintiff, Gregory Milligan, in the above-captioned matter. DATE Date A Respectfully submitted, ABOM & KUTUM"S, LLP Kara W. Haggerty, E?ya?re? 36 S. Hanover Street -?J Carlisle, PA 17013 (717) 249-0900 ID No. 86914 V\_1 Michelle L. Sommer, 4 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 c? r-Zt 1-n co c " GREGORY MILLIGAN : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO: 06-1380 TERESA MILLIGAN : CIVIL ACTION -LAW DEFENDANT : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER GREGORY MILLIGAN, Plaintiff, moves the Court to appoint a Master with respect to the following claims: [ x ] Divorce [ x ] Distribution of Property [ ] Annulment [ ] Support [ ] Alimony [ ] Counsel Fees [ ] Alimony Pendent Lite [ ] Costs and Expenses and in support of the Motion the Plaintiff states: 1. Discovery is complete as to the claim for which the appointment of a Master is requested. 2. The Defendant has appeared in the action personally. 3. The statutory ground for the divorce is: §§ 3301(c). 4. The action is contested with respect to the following claims: Distribution of Property 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 motions: DATE Am wo:o Michelle L. So er, Esquire Attorney for Plaintiff AND NOW, this day of , 2007, appointed Master with respect to the following claims: BY THE COURT, Esquire, is J. r-J 0 --V A t? N N e tD - . AUG 0 8 2VD?V GREGORY MILLIGAN : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO: 06-1380 TERESA MILLIGAN : CIVIL ACTION -LAW DEFENDANT : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER GREGORY MILLIGAN, Plaintiff, moves the Court to appoint a Master with respect to the following claims: [ x ] Divorce [ x ] Distribution of Property [ ] Annulment [ ] Support [ ] Alimony [ ] Counsel Fees [ ] Alimony Pendent Lite [ ] Costs and Expenses and in support of the Motion the Plaintiff states: 1. Discovery is complete as to the claim for which the appointment of a Master is requested. 2. The Defendant has appeared in the action personally. 3. The statutory ground for the divorce is: §§ 3301(c). 4. The action is contested with respect to the following claims: Distribution of Property 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 motions: DATE ?Q i\1 Michelle L. So er, Esquire Attorney for Plaintiff AND NOW, this a4d day of , 2007, Esquire, is appointed Master with respect to th following claims: BY COU , !').v I r.,AL J- C%j 15 - r: t C%j t U> ?TIL c? S (_ co 4 Ici, 'J _ ABOM ?' UTLILAKIs Michelle L. Sommer, Esquire Attorney I.D. No.: 93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 GREGORY MILLIGAN, Plaintiff V. TERESA MILLIGAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-1380 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE TO THE HONORABLE EDGAR BY BAYLEY, JUDGE OF SAID COURT: AND NOW, comes the Petitioner, GREGORY MILLIGAN, by and through his attorney, Michelle L. Sommer, Esquire, of ABOM & KUTULAKIS, L.L.P., and respectfully petitions for transfer of venue, and in support thereof avers the following. 1. Plaintiff is Gregory Milligan, who currently resides at 96 Pine Creek Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Teresa Milligan, who currently resides at 6592 Hollow Drive, East Petersburg, Lancaster County, Pennsylvania 17520. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. COUNT I - TRANSFER OF VENUE 4. Paragraphs one (1) through three (3) of this Complaint are incorporated herein by reference as though set forth in full. 5. Plaintiff and Defendant were married on July 3, 1995, in Villa Nova, Montgomery County, Pennsylvania. 6. Plaintiff and Defendant separated on June 18, 2004. 7. Upon separation, Plaintiff resided at 1419 North Second Street, Apartment #305, Harrisburg, Pennsylvania 17102, and continued to reside in Dauphin County until April 2007. 8. Plaintiff moved to Carlisle, Cumberland County, Pennsylvania in April 2007. 9. The initial divorce was filed by the Plaintiff, Gregory Milligan, on March 10, 2006, Docket Number 2006-1380 in Cumberland County, Pennsylvania. (A copy of the Divorce Complaint is attached hereto as "Exhibit A") 10. On June 28, 2007, the Plaintiff filed a Motion for an Appointment of Master for divorce and distribution of property. 11. On August 2, 2007, the Honorable Edgar B. Bayley appointed E. Robert Elicker, II as a Divorce Master. (A copy of the Motion is attached hereto as "Exhibit B"). 12. On October 5, 2007, undersigned counsel received a letter from Attorney Kurt Gardner that he had recently been retained by the Defendant to represent her divorce, Docket Number 2006-1380. 13. On October 11, 2007, both attorneys received a letter from Divorce Master Elicker indicating that since the parties were not residents of Cumberland County when the original Divorce Complaint was filed, Cumberland County would have discretion on whether or not the parties would be able to move forward with their case. (A copy of the Letter is attached hereto as "Exhibit C"). 14. The letter went on to further indicate that Cumberland County would not accept this case and suggested that the parties transfer the case to either Dauphin County or Lancaster County since that is where the parties resided initially at the time of the filing of the Divorce Complaint in 2006. WHEREFORE, Respondent respectfully requests this Honorable Court transfer jurisdiction over the above-docketed divorce action to Dauphin County, Pennsylvania. Respectfully submitted, DATE lQ_I 2-?0? ABOM & KUTULAKi4 L.L.P. Michelle L. So Supreme Court ID 93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff I, GREGORY MILLIGAN, verify that the statements made in this Petition Transfer of Venue 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. §4904 relating to unsworn falsification to authorities. Date \?" O v GREGORY MILLIGAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA ' 13 V. CIVIL TERM NO. MI TERESA MILLIGAN, CIVIL ACTION - LAW Y Defendant IN DIVORCE ' -- NOTICE TO DEFEND AND CLAIM RIGHTS = r1a 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 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, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 EXHIBIT A GREGORY MILLIGAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. CIVIL TERM TERESA MILLIGAN, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT 1. Plaintiff is Gregory Milligan, who currently resides at 1419 N. 2°d Street, #305, Harrisburg, Dauphin County, Pennsylvania 17102. 2. Defendant is Teresa Milligan, who currently resides at 5857 Vaughn Road, East Petersburg, Lancaster County, Pennsylvania 17520. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 3, 1995 at VillaNova, Montgomery County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, ? 3301(c), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since June 18, 2004 and continue to do so. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the.court require the parties to participate in such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from July 3, 1995, until June 18, 2004, the date of their separation, which property is "marital property" 12. Plaintiff and Defendant may have owned, prior to marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, the Plaintiff requests this Honorable Court to equitably divide all marital property. DATE 03 6, Respectfully submitted, ABOM & KUTULAA7s, L.L.P. Kara W. Haggerty 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ID No. 86914 VERIFICATION I, GREGORY MILLIGAN, verify that the statements made in this Divorce Complaint 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. § 4904 relating to unworn falsification to authorities. Date GREGORY MILLIGAN (: : IN THE COURT OF MMON PLEAS 0 2007pt( PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS. J?R 4, NO: 06-1380 A TERESA MILLIGAN : CIVIL ACTION -LAW DEFENDANT : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER M` GREGORY MILLIGAN, Plaintiff, moves the Court to appoint a Master with respect to the following claims: [ x ] Divorce [ x ] Distribution of Property [ ] Annulment [ ] Support [ ] Alimony [ J Counsel Fees [ ] Alimony Pendent Lite [ ] Costs and Expenses and in support of the Motion the Plaintiff states: C 'u- Ftr)r c. __4 ; ' ? 1. Discovery is complete as to the claim for which the appointment of a Masterrs_?eq u6s ed.0 2. The Defendant has appeared in the action personally. a 3. The statutory ground for the divorce is: §§ 3301(c). L 4. The action is contested with respect to the following claims: Distribution of Property 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 motions: DATE u 0 ja r Michelle L. So I er, Esquire Attorney for Plaintiff AND NOW, this ?Wclday of Al?, 2007, C - Imo LM_? ?_)/? , Esquire, is appointed Master with respect to the following claims: $? $ I t r ?oyF t ?. BY THE COURT, saga .aW,_. ?'= ' thew, t<ou?liste, Pa 04-c-l"eWy ? _77?? J. ad W a P OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240-6535 E. Robert Elicker, 11 Divorce Master Traci Jo Colyer Office Manager/Reporter October 11, 2007 Michelle L. Sommer Attorney at Law ABOM & KUTULAKIS, LLP 36 South Hanover Street Carlisle, PA 17103 RE: Gregory Milligan vs No. 06 -1380 Civil In Divorce Dear Ms. Sommer and Mr. Gardner: West Shore 697-0371 Ext. 6535 Kurt A. Gardner Attorney at Law GARDNER & STEVENS, P.C. 109 West Main Street Ephrata, PA 17522 Teresa Milligan Traci and. I discovered that this complaint should properly have been filed in either Dauphin County or Lancaster County. The complaint in divorce lists addresses for those counties respectively for the Plaintiff and Defendant. Although a county court can accept cases from other counties, they are not required to do so. It is discretionary with the Court as to whether or not they will allow non-resident litigants to file cases in Cumberland County. Our Court has indicated to me, after discussion on previous cases, that we will not accept cases in Cumberland County that properly belong in another county. Consequently, I suggest that you motion the Court to have the case transferred to either Dauphin or Lancaster County. We were going to send out a notice for a EXHIBIT 4 Ms. Sommer and Mr. Gardner, Attorneys at Law 11 October 2007 Page 2 rescheduled pre-hearing conference but I am not going to schedule that conference considering the current status of this case. Very truly yours, E. Robert Elicker, II Divorce Master - GREGORY MILLIGAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 06-1380 CIVIL TERM TERESA MILLIGAN, CIVIL ACTION - LAW Defendant IN DIVORCE The undersigned hereby certified that on this date, a true and correct copy of the foregoing Petition for Transfer of Venue was served by first class mail to the following: Kurt A. Gardner, Esquire GARDNER & STEVENS, P.C. 109 West Main Street Ephrata, PA 17522 Attorney for Defendant Dated: Respectfully submitted, Abom & Kutulakis, L.L.P. Michelle L. Sommer, squire Attorney ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for the Plaintiff Z n GREGORY MILLIGAN, IN THE COURT OF COMMON LEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. TERESA MILLIGAN, DEFENDANT 06-1380 CIVIL TERM ORDER OF COURT AND NOW, this L day of June, 2008, a Rule is entered against Teresa Milligan to show cause why the within case should not be transferred to the Court of Common Pleas of Dauphin County. Rule returnable ten (10) days after service. By the Burt, r Michelle L. Sommer, Esquire For Plaintiff Edgar B. Bayley, J. , ?Kurt A. Gardner, Esquire For Defendant E. Robert Elicker, II, Esquire Divorce Master _ bony ' 67 k -'!r c :sal l ?0 c ES r» ?t ?k ?/IS?OS Q r Y L?j T? JSI iv TAB 2OM & &N i ULAKIS Michelle L. Sommer, Esquire Attorney I.D. No.: 93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 GREGORY MILLIGAN, Plaintiff V. TERESA MILLIGAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-1380 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE TO THE HONORABLE EDGAR BY BAYLEY, JUDGE OF SAID COURT: AND NOW, comes the Petitioner, GREGORY MILLIGAN, by and through his attorney, Michelle L. Sommer, Esquire, of ABOM & KUTULAKIS, L.L.P., and respectfully avers the following: 1. Petitioner, by and through his counsel, filed a Petition for Transfer of Venue to Dauphin County on June 12, 2008. 2. On June 17, 2008 an Order was entered against the Defendant to show cause why the case should not be transferred to Dauphin County. The Rule was returnable within 10 days of service. 3. More than 10 days have elapsed and Defendant has not filed a response to the Rule to Show Cause. Y ti WHEREFORE, Respondent respectfully requests this Honorable Court transfer jurisdiction over the above-docketed divorce action to Dauphin County, Pennsylvania. DATE 3 a ? q a Respectfully submitted, ABOM & KUTULAKn3 L.L.P. C Jmlifimp i IhAIwV6_) - Michelle L. Sommer squire Supreme Court ID 93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 GREGORY MILLIGAN, Plaintiff V. TERESA MILLIGAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-1380 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE The undersigned hereby certified that on this date, a true and correct copy of the foregoing Motion to Make Rule Absolute was served by first class mail to the following: Kurt A. Gardner, Esquire GARDNER & STEVEN P. C. 109 West Main Street Ephrata, PA 17522 Attorney for Defendant Dated: -q_, Dq- big Respectfully submitted, Abom & Kutulakis, L.L.P. MA MA )Attorney chelle L. Sommer, squire ID No. 9 034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for the Plaintiff r? <?:. s.-:? ?? i:?:? r'a ? _ ..4,..,/ {._.« -ter ..-;ice. r? r?-s . c:a rte. ;:?;: ? ,?` '? ?, ?'i= :.?.' JUL 2 1 2008 GREGORY MILLIGAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 06-1380 CIVIL TERM TERESA MILLIGAN, CIVIL ACTION - LAW Defendant IN DIVORCE ORDER OF COURT AND NOW, this ZZ day of July, 2008, upon consideration of the within Motion to Make Rule Absolute, said Motion is hereby GRANTED. The Prothonotary is hereby instructed to transfer the file to Dauphin County. Counsel for both Plaintiff and Defendant shall be notified upon said transfer. istribution: Michelle L. Sommer, Esquire, Attorney for Plaintiff ? Burt A. Gardner, Esquire, Attorney for Defendant 7 f a??os U L.... fd?L. 4 i c?s c