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Home My WebLink About06-2147Y STELLA MOLINARES, Plaintiff VS. ALVARO MOMNARES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION- AT 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 fait 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 Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 STELLA MOLINARES, Plaintiff vs. ALVARO MOLMARES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Oto - ?l yo u '? l ?zn CIVIL ACTION- AT LAW- IN DIVORCE DIVORCE COMPLAINT WITH EQUITABLE DISTRIBUTION CLAIM The Plaintiff, Stella Molinares, by and through her attorneys, The Law Offices of Patrick F. Lauer, Jr., makes the following Complaint in Divorce: COUNT I-NO FAULT DIVORCE--§§ 3301(c) or 3301(d) 1. The Plaintiff, Stella Molinares, is an adult individual currently residing at 475 Spruce Road, New Cumberland, Cumberland County, Pennsylvania, 140-1-3. 1 ; c 'c 2. The Defendant, Alvaro Molinares, is an adult individual currently residing at 347 Wyatt Road, Harrisburg, Dauphin County, Pennsylvania, 17104. 3. The parties 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 parties were married on August 22, 1975 in Roselle, New Jersey 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. 9. The Defendant is retired from the United States Army. 10. There are no minor children. WHEREFORE, the Plaintiff requests this Honorable Court enter a decree of Divorce in this matter. COUNT II-EQUITABLE DISTRIBUTION--§ 3502(a) 11. Paragraphs one (1) through ten (10) of this Complaint are incorporated herein by reference as if set forth specifically below. 12. During the course of the marriage, the parties acquired property and incurred debt, titled jointly, individually, or both, which remains in possession of the individual parties. WHEREFORE, the Plaintiff respectfully requests the Court to equitably divide, distribute, or assign the marital property between the parties in such proportion as the court deems just after consideration of all relevant factors and thereby enter an order of equitable distribution of marital property pursuant to §3502(a) of the Divorce Code. COUNT III-REQUEST FOR ALIMONY PENDETE LITE AND ALIMONY PURSUANT TO SECTIONS 3701(a) and 3702 OF THE DIVORCE CODE 13. Paragraphs one (1) through twelve (12) of this Complaint are incorporated herein by reference as if set forth specifically below. 14. Plaintiff is unable to sustain herself during the course of litigation. 15. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 16. Plaintiff requests the Court to enter an award of alimony pendente lite until final hearing and thereupon to enter an order of alimony in his favor pursuant to Sections 3701(a) and 3702 of the Divorce Code. WHERFORE, Plaintiff respectfully requests this Honorable Court to enter an award of alimony pendente lite until final hearing and thereupon to enter an order of alimony in his favor pursuant to Sections 3701(a) and 3702 of the Divorce Code. Respectfully submitted, Shana M. ugh, "Esq- ulLaw Offices of Patrick . Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011 Date: - ` 1 ID# 200952 Tel. (717) 763-1800 STELLA MOLINARES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. ALVARO MOLINARES, : CIVIL ACTION- AT LAW- IN DIVORCE Defendant 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. § 4904, relating to unsworn falsification to authorities. Date: I a C Signature: Stella Molinares Tj .? I. o ?f - e STELLA MOLINARES, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 06 - 2147 Civil Term ALVARO MOLINARES, : CIVIL ACTION - AT LAW IN DIVORCE Defendant PETITION TO WITHDRAW APPEAR ANC TO THE HONORABLE JUDGES OF SAID COURT: AND NOW, comes Petitioner, Marlin L. Markley, Esquire, an Associate Attorney with the Law Offices of Patrick F. Lauer, Jr., LLC and, in support of his Petition to Withdraw Appearance, respectfully represents as follows: 1. Petitioner is Marlin L. Markley, Esquire, an Associate Attorney with the Law Offices of Patrick F. Lauer, Jr., LLC. 2. Respondent, Stella Molinares resides at 475 Spruce Road, New Cumberland, Pennsylvania 17070. 3. Respondent retained Attorney Shana M. Pugh a former Associate Attorney with the Law Offices of Patrick F. Lauer, Jr., LLC on or about April 4, 2006, to represent her in connection with the filing of a divorce complaint. 4. A Complaint in Divorce was filed with this Honorable Court on or about April 13, 2006 thereby instituting the above-captioned action. 5. In October of 2006, Attorney Shana M. Pugh accepted an Associate Attorney position with Attorney Nora Frances Blair's office located at 5440 Jonestown Road, Harrisburg, Pennsylvania 17112-0216. 6. During a telephone conversation on October 9, 2006, between the Petitioner and Respondent, Respondent indicated that she was uncertain whether she was going to continue to use the Law Offices of Patrick F. Lauer, Jr., LLC, to represent her for her divorce. 7. On October 9, 2006, Petitioner sent a letter to Respondent confirming the telephone conversation and requesting that Respondent advise Petitioner of her decision. See Exhibit "A". 8. On February 7, 2007, Petitioner sent a letter to Respondent asking Respondent to contact Petitioner to discuss the status of Respondent's case. See Exhibit "B". 9. Respondent has been unresponsive to both of Petitioner's attempts to contact her. 10. Petitioner has at all times attempted to represent Respondent effectively and vigorously to the best of his ability. 11. Petitioner asks to withdraw his appearance for Stella Molinares because, inter alia: a. In the only communication between Petitioner and Respondent, Respondent indicated that she was uncertain whether she wanted Petitioner to represent her. b. Petitioner has requested that Respondent contact the office to discuss legal proceedings and Respondent does not respond. C. Continued representation will result in an unreasonable financial burden on Petitioner. 12. Petitioner is not aware of a Judge ruling on any issue related to this matter. 13. There has been no entry of appearance or any other indication of anyone representing the Defendant. WHEREFORE, Petitioner respectfully requests that the appearance of the Law Offices of Patrick F. Lauer, Jr., LLC be withdrawn and removed from the docket as the attorney of record for Stella Molinares. Respectfully Submitted: Marlin Lflblaley, Esquire Law Offices o Patrick F. Lauer, Jr., LLC 2108 Market Street Camp Hill, PA 17011 ID# 84745 Tel. (717) 763-1800 Date: May 3, 2007 STELLA MOLINARES, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 06 - 21.47 Civil Term ALVARO MOLINARES, : CIVIL ACTION - AT LAW IN DIVORCE Defendant I, Marlin L. Markley, Esquire, hereby certify that on the below-noted date I served the foregoing Petition to Withdraw Appearance by depositing a true and exact copy thereof in the United States Mail, first class, postage prepaid, addressed as follows: Stella Molinares 475 Spruce Road New Cumberland, PA 17070 Alvaro Molinares 347 Wyatt Road Harrisburg, PA 17104 Respectfully Submitted: Marli kley, Esquire Law Offic of Patrick F. Lauer, Jr., LLC 2108 Mar t Street Camp Hill, PA 17011 ID# 84745 Tel. (717) 763-1800 Date: May 3, 2007 Exhibit A THE LAW OFFICES OF PATRICK F. LAUER, JR., L.L.C. 2108 MARKET STREET, AZTEC WELDING CAMP HILL, PENNSYLVANIA 17011 Patrick F. Lauer, Jr., Esq.* (717) 763-1800 FAX (717) 763-4247 Satellite Office: Marlin L. Markley, Esq.** Reply to Camp Hill Address 8 S. Hanover Street Carlisle, PA 17013 1-800-822-4-LAW October 9, 2006 Stella Molinares 475 Spruce Road New Cumberland, PA 17070 gtwer_dni-na _cnm Dear Ms. Molinares: I appreciate you taking the time to discuss your case with me today. As you are now aware Attorney Pugh is no longer with my office. I will be taking over her cases that stay with our office. I am a Senior Associate at The. Law Offices of Patrick F. Lauer, Jr., LLC. I have been employed here as an attorney for six and a half (61/2) years and during those six and a half (61/2) years I have practiced family law. It is my understanding that Attorney Pugh bills you at a rate of $125.00 an hour minus the 25% through CLC for a total of $93.75 an hour. I currently bill at an hourly rate of $185.00 an hour however, I am willing to bill you at the $93.75 an hour rate for the next six months if you decide to stay with out office. If you decide to use a different law firm please provide us with your new attorney's information and I would certainly provide you the documentation that you have already submitted to my office. Please let us know your decision. MLM/ben *EPBoard Certified as a Criminal Trial Advocate by the National Board of Trial Advocacy. * * 4DMember: National Association of Criminal Defense Lawyers Ex ibi+ B THE LAW OFFICES OF PATRICK F. LAUER, JR., L.L.C. 2108 MARKET STREET, AZTEC BUILDING CAMP HILL, PENNSYLVANIA 17011 Patrick F. Lauer, Jr., Esq.* (717) 763-1800 FAX (717) 7634247 Satellite Office: Marlin L. Markley, Esq.** Reply to Camp Hill Address 8 S. Hanover Street Carlisle, PA 17013 1-800-822-4-LAW ww ii_na rtnm February 7, 2007 Stella Molinares 475 Spruce Road New Cumberland, PA 17070 Dear Ms. Molinares: I previously sent you a letter on October 9, 2006 in regard to your pending divorce in Cumberland County Court. I have not received a response. Please contact me immediately to discuss how you wish to proceed. Very truly yours, Marlin L. Markley, Esquire MLM/san * Board Certified as a Criminal Trial Advocate by the National Board of Trial Advocacy. * * 4bMember: National Association of Criminal Defense Lawyers STELLA MOLINARES, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ALVARO MOLINARES, : Defendant NO. 06-2147 CIVIL TERM ORDER OF COURT AND NOW, this 9 h day of May, 2007, upon consideration of the Petition To Withdraw Appearance, a Rule is hereby issued upon all parties to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, M lin L. Markley, Esq. . 08 Market Street Camp Hill, PA 17011 tella Molinares 475 Spruce Road New Cumberland, PA 17070 ,A ?varo Molinares / 347 Wyatt Road Harrisburg, PA 17104 rc o/ f ? ? 'r?Rliw? -w, ao STELLA MOLINARES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 06 - 2147 Civil Term ALVARO MOLINARES, : CIVIL ACTION - AT LAW IN DIVORCE Defendant PRAFCIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of the Law Offices of Patrick F. Lauer, Jr., LLC on behalf of the Plaintiff in the above-captioned action as Stella Molinares is entering her appearance Pro Se. Respectfully submitted, arlin L arkl , Esquire Law Offices atrick F. Lauer, Jr., LLC 2108 Mar Street _ Camp Hill, Pennsylvania 17011 Date: 5 Li IV 1 0 ID# 84745 Tel. (717) 763-1800 TO THE PROTHONOTARY: Please enter the appearance of Stella Molinares, Pro Se in the above-captioned action. Respectfully submitted, ,,-,Stella Molinares, Pro Se 475 Spruce Road New Cumberland, Pennsylvania 17070 Date: `5 1 Tel. (717) 932-1019 r? t=' ti ?e STELLA MOLINARES, : IN THE COURT OF COMMON PLEAS OF PlaintifflRespondent : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 06 - 2147 Civil Term ALVARO MOLINARES, : CIVIL ACTION - AT LAW IN DIVORCE Defendant TO THE PROTHONOTARY: Please withdraw the Petition to Withdraw Appearance filed on May 4, 2007, as the Plaintiff, Stella Molinares has entered her appearance Pro Se. Respectfully sub ' d, f .f 6M ey, Esquire M On' Law Offices f Patrick F. Lauer, Jr., LLC 2108 Market Street Camp Hill, Pennsylvania 17011 Date: 0J ID# 84745 Tel. (717) 763-1800 v `?I - ° _ ? s .. _, , ?':- __. .:... ,. ? _ _ _,. _ -?; L". -k i STELLA MOLINARES, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Respondent : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 06 - 2147 Civil Term ALVARO MOLINARES, : CIVIL ACTION - AT LAW IN DIVORCE Defendant TO THE PROTHONOTARY: I, Marlin L. Markley, Esquire, verify that the Complaint in Divorce has been served upon the Defendant indicated above by first class, certified mail # 7005-0390-0006- 3485-5155, return receipt, restricted delivery, pursuant to the requirements of Pa. R.C.P. 1930.4. • Complete items 1.2. and 3. Also complete Item 4 M Restricted Delivery Is desired. ¦ PM your rrems and address on the reverse so that we can retum the kid to you. ¦ Attach this card to the track of the mailpiec% or on the front N space permits. 1. Article Addressed to '4 01 /var 0 Q-t?- X ? Agent C. Date of Delivery L (?PMY?[edM id 1-17 Z)4o D. is delivery address di ferent from Item 1? ? Yes If YES, enter delivery address below: ? No o me" 1-710 q ? Maured Mall ? C.C.D. _ a RnblaMd DaNMSy4 PDOn F sil 2. MArticle u (/IwAfar Aarr/ ffl aaMor. 660 arleAr 7005 0390 0006 3485 5155 Ps Form 3811. February 2004 Dome stic Raaxn Receipt 102595.02ru.ts0; Respectfully Date: A 4 ? ) u 2 X07 Mar rinMarkley, Esquire Law Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 ry is ! MAY ISWO? STEPHANIE L. DONNELLY, Plaintiff VS. MARK R. DONNELLY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-2472 MOTION FOR ENTRY OF QUALIFIED DOMESTIC RELATIONS ORDER AND NOW comes the above-named Defendant, by his attorney, Samuel L. Andes, and moves the court to enter the attached Qualified Domestic Relations Order to implement one of the terms of the Property Settlement Agreement entered by the parties at the time of their divorce. Judge Bayley signed the divorce decree between the parties. Both parties concur in the entry of the Qualified Domestic Relations Order. %, 1, JQMO L. An s Attorney for Defendant Supreme Court ID # 17225 525 North 12'' Street Lemoyne, Pa 17043 (717) 761-5361 U_ CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon counsel for the Plaintiff by regular mail, postage prepaid, addressed as follows: Ruby D. Weeks, Esquire P.O. Box 397 Carlisle, PA 17013 Date: 1 May 2007. Amy M. kins Se etary for Samuel L. Andes 684075328 CASE NO. 2006-2472 Court of Common Pleas Of Cumberland County, Pennsyl- vania Stephanie L. Donnelly ) PA QUALIFIED PA VS. ) DOMESTIC RELATIONS ORDER Mark R. Donnelly ) WHEREAS, this Court has jurisdiction over the parties and the subject matter of this Order; and WHEREAS, the parties and the Court intend that this Order shall be a Qualified Domestic Relations Order (hereinafter referred to as a "QDRO") as defined in Section 206(d)(3) of the Employee Retirement Income Security Act of 1974, as amended ("ERISA") and Section 414(p) of the Internal Revenue Code of 1986, as amended; and, WHEREAS, pursuant to the referenced statutes, the Plan Administrator shall make a determination of the qualified status of this Order; and WHEREAS, following approval by the Plan Administrator, this Order shall constitute a Qualified Domestic Relations Order; and WHEREAS, the parties have stipulated that the Court enter this Order; NOW, THEREFORE, pursuant to this state's Domestic Relations Laws, IT IS HERE BY ORDERED BY THE COURT as follows: 1. As used in this Order, the following terms shall apply: (a) "Participant" shall mean Mark R. Donnelly, whose current address is 707 West Pine Street, Mount Holly Springs, PA 17065. (b) "Alternate Payee" shall mean Stephanie L. Donnelly, whose current address is 102 Fair- field Street, Newville, PA 17241. (c) "Plan" shall mean Yellow Roadway Corporation Retirement Savings Plan. 2. The Order relates to marital property rights 3. The date of marriage was 08/20/1994. 4. The date of legal separation or divorce is 09/27/2006. 5. The Alternate Payee is the former spouse of the Participant. 6. With respect to marital property, alimony and spousal awards, the Participant and the Alternate Payee are/were married for federal income tax purposes. 7. The Alternate Payee's award will be calculated as of the date the award is segregated into the Alternate Payee's account. The date of segregation shall hereinafter be referred to as the "Valuation Date". 8. The Alternate Payee's interest in the Plan shall be $61,368.00 of the Participant's total vested account balance under the Plan as of the Valuation Date. 9. The Alternate Payee's award is not entitled to earnings (dividends, interest, gains and losses) from the Valuation Date to the date that the award is segregated from the Partici- pant's account. From and after the date of segregation, the Alternate Payee's award shall be held in an account under the Plan and shall be entitled to all earnings attributable to the investments therein. 10. In the event there is an outstanding loan balance as of the Valuation Date, the loan bal- ance will be included for purposes of calculating the account balance to be divided. The Alternate Payee's award will be paid from the non-loan assets in the Participant's ac- count on the date that the award is segregated from the Participant's account. 11. The Alternate Payee's award will be paid proportionately from all standard plan invest- ment options in which the Participant's account is invested (not including the Broker- ageLink account). In the event that the Participant has a BrokerageLink account and there are insufficient funds in the standard plan investment options in the Participant's account to satisfy the Alternate Payee's award, the Participant is hereby ORDERED to immediately transfer sufficient funds from the BrokerageLink account to the standard plan investment options to satisfy the Alternate Payee's award. 12. The Alternate Payee shall have the right to select from the available benefit forms pro- vided under the terms of the Plan at the time the Alternate Payee becomes eligible and elects a distribution. The Alternate Payee shall initiate the distribution in accordance with the terms of the Plan and the administrative procedures that have been established by the Plan Administrator. The amount distributed to the Alternate Payee will be based on the value of the Alternate Payee's account on the date the distribution is processed. 13. All beneficiary designations will be made after qualification of the Order and segrega- tion of a separate account for the Alternate Payee pursuant to the administrative proce- dures established for the Plan. 14. The Parties shall cause an original court certified or true copy of this Order to be served on the Plan Administrator's agent, Fidelity Employer Services Company LLC, forth- with. This Order shall remain in effect until further order of this Court. 15. Nothing contained in the Order shall be construed to require any Plan or Plan Adminis- trator to provide to the Alternate Payee any type or form of benefit or option not other- wise available under the Plan, to provide the Alternate Payee increased benefits (determined on the basis of actuarial value) not available to the Participant, or to pay any benefits to the Alternate Payee that are required to be paid to another Alternate Payee under another Order, which has been determined to be a QDRO before this Order is determined to be a QDRO. 16. Neither Party shall accept any benefits from the Plan which are the property of the other Party. In the event that the Plan Administrator inadvertently pays to the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms of this Order, the Participant shall forthwith return such benefits to the Plan. In the event that the Plan Ad- ministrator inadvertently pays to the Alternate Payee any benefits that are not assigned to the Alternate Payee pursuant to the terms of this Order, the Alternate Payee shall forthwith return such benefits to the Plan. 17. The Plan and its sponsor and fiduciaries shall not be responsible for any attorney's fees incurred by the Participant or the Alternate Payee in connection with obtaining, modify- ing and enforcing this Domestic Relations Order. 18. For purposes of Sections 402 and 72 of the Internal Revenue Code, any Alternate Payee who is the spouse or former spouse of the Participant will be treated as the distributee of any distributions or payments made to the Alternate Payee under the terms of this Or- der, and as such, will be required to pay the appropriate federal and/or state income taxes on such distribution. If the Alternate Payee is a child or other dependent of the Participant, the Participant will be responsible for any federal and/or state income taxes on any such distribution. 19. The Court shall retain jurisdiction with respect to this Order to the extent required to maintain its qualified status and the original intent of the parties as stipulated herein. Attorney For Alternate Payee: Attorney For Participant: Ruby D. Weeks P.O.Box 397 Samuel L. Andes 525 North 12th Street, P.O. Box 168 Carlisle, PA 17013 Lemoyne, PA 17043 Dated: Judge Of the Court: Track No: 684075328 Accepted and ordered this ?IAday of CONSENT TO ORDER: Taint' Alternate Payee to Attorney Mr Plaintiff/ Date Alternate Payee Aftbij?ey for De ndant/ Da Participant Defendant/Participant Date r t-i?J ZL.i ? -•` ' LL- r e 7--A Todd C. Hough, Esquire Attorney I.D. No. 91060 Jay R. Braderman, Esquire Attorney I.D. No. 07047 Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 Tel: 717-233-6633 Fax: 717-233-7003 Attorneys for Plaintiff STELLA MOLINARES, Plaintiff vs. ALVARO MOLINARES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 06-2147 CIVIL TERM IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearances of Todd C. Hough, Esquire and Jay R. Braderman, Esquire, as attorneys for Plaintiff, Stella Molinares, in the above-captioned action. Date: zy off'' 'odd C. Hough, Esquire Attorney I.D. No.: 91060 Jay R. Braderman, Esquire Attorney I.D. No.07047 Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 Tel: 717-233-6633 Fax: 717-233-7003 r r 1 CERTIFICATION I hereby certify that I am this day serving a true and correct copy of the attached Praecipe For Entry Of Appearance on the following individual by First Class U.S. Mail addressed as follows: Alvaro Molinares P. O. Box 1311 Harrisburg, PA 17105 Date: zy v /?? Todd C. Hough, Esquire Attorney I.D. No. 91060 Jay R. Braderman, Esquire Attorney I.D. No.07047 Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 Tel: 717-233-6633 Fax: 717-233-7003 Attorneys for Plaintiff r? "?,? r° _ .....?.. a..:?'1 ?? .. ?e '? Diane S. Baker, Esquire I.D. No. 53200 27 S. Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 STELLA MOLINARES, Plaintiff VS. ALVARO MOLINARES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-2147 CIVIL ACTION -LAW DIVORCE PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance on behalf of the Defendant, Alvaro Molinares, in the above-referenced matter. submitted, DATE: //?/t bS/ L#116 D. Jacobson, Esquire `i 7 No. 52,o 81 0 Derry Street ite A Harrisburg, PA 17111 ! .- % STELLA MOLINARES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2006-2147 ALVARO MOLINARES, Defendant : CIVIL ACTION - DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendant, Alvaro Molinares, in the above- referenced matter. DATE: it Ilq?°? Llano a. naxcr, zsqulre I.D. No. 53200 27 S. Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 <xy I,01 W , i?? i Todd C. Hough, Esquire Jay R. Braderman, Esquire Lavery, Faherty, Young & Patterson, P. C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 Attorneys for Plaintiff STELLA MOLINARES, Plaintiff vs. ALVARO MOLINARES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 06-2147 CIVIL TERM IN DIVORCE NOTICE OF SERVICE OF GENERAL INTERROGATORIES (FIRST SET) FROM PLAINTIFF TO DEFENDANT TO: Curt Long, Prothonotary Dear Sir: Please be advised that on this day an original and two copies of the General Interrogatories (First Set) from Plaintiff to Defendant were served via U. S. Mail, First Class, upon the following individual: Diane Sommers Baker, Esquire 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 Respectfully submitted, Lavery, Faherty, Y DATE: /Z 12'V /A? By: TloddC. Hough, Esquire Attorney No. 91060 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 Attorneys for Plaintiff , P.C. --?_, :a .. _?? ?-, e-a ;a??, '?'?' r ?,'?' - ., Todd C. Hough, Esquire Jay R. Braderman, Esquire Lavery, Faherty, Young & Patterson, P.C. 225 Market Street, Suite 304 P. O. Box 1245 Harrisburg, PA 17108-1245 Attomeys for Plaintiff STELLA MOLINARES, Plaintiff vs. ALVARO MOLINARES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 06-2147 CIVIL TERM IN DIVORCE NOTICE OF SERVICE OF PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANT TO: Curt Long, Prothonotary Dear Sir: Please be advised that on this day an original and two copies of the Plaintiffs First Request for Production of Documents Directed to Defendant were served via U. S. Mail, First Class, upon the following individual: Diane Sommers Baker, Esquire 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 Lavery, Faherty, Y G DATE: /f?F Respectfully submitted, By: Patterson, P.C. Todd C. Hough, EsSquire Attorney No. 91060 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 Attorneys for Plaintiff cw _ o ? STELLA MOLINARES, IN THE COURT OF COMMON PLEAS Plaintiff CUMBF,RLAND COUNTY, PENNSYLVANIA vs. NO. 2006-2147 ' - ' '=:; -:5 ALVARO MOLINARES, :CIVIL ACTION -LAW ---- Defendant IN DIVORCF, _. STATEMENT OF INTENTION TO PROCEED TO THE PROTHONOTARY: Accept this filing as evidence that the Defendant, Alvaro Molinares, intends to 4~~roceed in the above referenced matter. Respectfully submitted, DATE: r .._ 1 s:~ Baker, Esquire LD. No. 53200 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 171.12-0443 {717) 671-96Q0 BakerLawOffice@aol.com