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HomeMy WebLinkAbout06-2954 DAVID E. GLASSER, Plaintiff VS. KITTY M. GLASSER, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA. : NO. OL- 29SY : CIVIL ACTION - LAW : IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HERE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 DAVID E. GLASSER, Plaintiff VS. KITTY M. GLASSER, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNA. : NO. : CIVIL ACTION - LAW : IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las piginas siguientes, debe tomar acci6n con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decisi6n puede tambien ser emitida en su contra por cualquier otra queja o compensaci6n reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una Iista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013. SI USTED NO RECLAMA PENSION ALWENTICIA, PROPIEDAD MARITAL HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIEENTO SEA MEITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAREL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 DAVID E. GLASSER, Plaintiff vs. KITTY M. GLASSER, Defendant : IN TBE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY PENNA. NO. CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c)OF THE DIVORCE CODE COUNTI AND NOW, this ?a of y , 2006, comes the Plaintiff, David E. Glasser, by his attorney, Jane M. Alexander, Esquire, and files this Complaint upon a cause of action of which the following is a statement. 1. Plaintiff is David E. Glasser, 34 years of age, who currently resides at 711 Bloserville Road, Newville, Upper Frankford Township, Cumberland County, Pennsylvania 17241. 2. Defendant is Kitty M. Glasser, 26 years of age, who currently resides at 219 N. West Street, Carlisle, Carlisle Borough, Cumberland County, Pennsylvania 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 2, 2002 in New Kingston, Cumberland County, Pennsylvania by a Reverend. 5. There was one (1) child born between the parties during this marriage: Donavan J. Glasser, age 3, born September 28, 2002. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The parties have not entered into a written agreement as to alimony, counsel fees, costs and property division. 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 counseling. 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render his condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT U 10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference and made a part hereof. 11. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT III 12. The allegations of Paragraph one (1) through eleven (11) are incorporated herein by reference and made a part hereof. 13. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Chapter 35 of the Divorce Code. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property of whatsoever kind and whosesoever situate and for such further relief as the Court may deem equitable and just. Respectfully submitted, ttomey for PlkintifV .D. No. 07355 48 South Baltimore Street Dillsburg, PA 17019 (717) 432-4514 VERIFICATION I verify that the statements made in this Complaint in Divorce 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 falsification to authorities. DATE: -V121'1)6 avid E. la ser COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK S.S. Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared David E. Glasser who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. Sworn to and subscaed befQre,ffle this /7 day of YW- 2006. Public avid E. Glasser Notarial Seal Leslie K. NeiUig, Notary Public Warrington Twp, York County My Commission Expires Feb. 4, 2007 Member, pannsylvania Association tX Notaries t? 1J `' Q l`i M> DAVID E. GLASSER, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMB RLAND COUNTY, PENNA v5. : NO. 06-29 4 Civil Term KITTY M. GLASSER, : CIVIL AC?ON - LAW Defendant : IN DIVOR E AND NOW, this j ay of appeared Jane M. Alexander, Esquire who swears accord copy of a COMPLAINT IN DIVORCE was caused to be receipt requested upon the said, Kitty M. Glasser 219 N. West Street Carlisle, PA 17013 on May 24, 2006 by leaving the same at the Dillsburg Post 2006 personally law, that a true and correct by certified mail with return with postage pre-paid thereon as evidenced by the mailing receipt and return receipt hereto attached and made a part hereof. '148 S. Bal Dillsburg, (717)432- Sworn and subscribed before me this Soh` day of W a,?= 2006. Notary Public COMMONWEALTH Of PENNSYLVANIA Notarial Sad nd Alexander, Notary RbAC ana LN Dlbblxp Boro, Yak Courtly Canmladon Expires Apr.7, 2010 Member, PennaylVanie ASSObiaNen of NetadM are Street 17019-0421 4 ' M ' 'M v '"C? rT -ri C 1 ', n G i %4 a ?y r DAVID E. GLASSER, VS. KITTY M. GLASSER, : IN THE : OF CW NO. 06-: CIVII. i Defendant : IN DIVOT PROOF OF SERVICE Plaintiff ? m a}T71P.7!?1 S per M .A Postage $ M 0 OarOW Fes $2.40 0 Retum Redept Fee RV $1.85 (EMOreenxaN . 0 Reasloted DeIW y Fee d u•) (Endorsement Regeeed) 0 Total Postage A Feas $ 7 0019 01 ?4 171 ww'Ww.; orMft Alm Ia N' West 5kte?t --- .------- `cyseie;zirv6?y?rli5le, ?A 1'10(3 - ------------- OF COMMON PLEAS ND COUNTY, PENNA Civil Term -LAW 7004 0750 0003 6356 4365 1,1 1 c- ? -n -71 : _.. rt7 z „Y N C? DAVID E. GLASSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 06 - 2954 ivil Term KITTY M. GLASSER, : IN DIVORCE Defendant NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated on April 22, 2006 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose my 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 herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date 6-/ zv 4 4 L?-, i M. Glasser, Defendant 3 .° - -? t t ? e .a. -? . ?,,,4', ld... ' * ""S7 .?" ? Q -? DAVID E. GLASSER, Plaintiff V. KITTY M. GLASSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA' C7- No. 06 - 2954 Civil Term ' IN DIVORCE r )R APPOINTMENT OF MASTER 2 rv r- Defendant moves this Court to appoint a master with respect to the following claims: X/) Divorce 1\el Distribution of Property i 1 Annulment ( ) Support ( } Alimony ( ) Counsel fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion sta es: (1) Discovery is substa tially complete as to the claim(s) for which the appointment of a master is requested. (2) The Plaintiff is represented by Jane Alexander, Esquire. (3) The statutory ground(s) for divorce is 3301 (d). (4) Delete the inapplicable paragraph(s): (b) An agreeme t has been reached with respect to the following claims: NONE. (c) The action is contested with respect to the following claims: ALL. (5) The action does not i (6) The hearing is expect (7) Additional information Date: AND NOW, this respect to the following claims: 2010, Robert Elicker, Esquire, is appointed Master with BY THE COURT: solve complex issues of law or fact. d to take one-half day. if any, relevant to the motion: NONE. fin Adams, Esquire - 7 . South St. Carlisle, Pa. 17013 rney for Defendant 17) 245-8508 ORDER APPOINTING MASTER J. MAR 2 4 2010 y DAVID E. GLASSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA o c V. : No. 06 - 2954 Civil Term KITTY M. GLASSER, : IN DIVORCE w Defendant r MOTION FOR APPOINTMENT OF MASITER tV Defendant moves this Court to appoint a master with respect tolthe following claims: Divorce (`) Divorc Annulment (\A Distribution of Property ( ) ( )Support Alimony ( ) Counsel fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery is substantially complete as to the claim(s) for wh4h the appointment of a master i; requested. (2) The Plaintiff is represented by Jane Alexander, Esquire. (3) The statutory ground(s) for divorce is 3301 (d). (4) Delete the inapplicable paragraph(s): (b) An agreement has been reached with respect to the fl (lowing claims: NONE. (c) The action is contested with respect to the following caims: ALL. (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take one-half day. (7) Additional information. if any, relevant to the motion: NONE. Date: t O all uth St s 7 S Carlisle, Pa. 17013 rney for Defendant 17) 2415-8508 4 ORDER APPOINTING MASTER o M En a AND NOW, this z F.. ;;0 2&ddllk. ?If 2010, Robert Elicker, Esquire, is appointed A I— wit?g respect to the following claims: ALL. BY THE COURT:; rI is e0mcI t' f ? -" G A? J. )qe-&' ,s 144_( J. A "ik / . J. 2112r1 lo ?::Xeq m -o d" U t DAVID E. GLASSER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06 - 2954 CIVIL : KITTY M. GLASSER, Defendant IN DIVORCE 9?P Y THE MASTER: Today is Friday, May 21, 2?O 1D'. F This is the date set for a conference in the above-captioned' divorce proceedings. Present in the hearing room are the Plaintiff, David E. Glasser, and his counsel Jane Alexander and the Defendant, Kitty M. Glasser, and her counsel Jane Adams. This action was commenced by the filing of a complaint in divorce on May 23, 2006, raising grounds for divorce of irretrievable breakdown of the marriage. The parties have signed affidavits of consent and waivers of notice of intention to request entry of divorce decree dated May 21, 2010. The affidavits and waivers will be filed with the Prothonotary by the Master's office. The divorce can, therefore, conclude under Section 3301(c) of the Domestic Relations Code. It is noted that an affidavit of separation was filed on May 6, 2008, averring the parties separated on April 22, 2006, a period in excess of two years. However,, since we have the signed consents and waivers, we are going to proceed under Section 3301(c). The complaint also raised an economic claim 1 of equitable distribution. No claims have been raised by either party for alimony or counsel fees and expenses. The Master has been advised that the parties have reached an agreement with respect to the outstanding economic claims. The agreement is going to be placed on the record in the presence of the parties. The agreement as stated on the record will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Consequently, when,the parties leave the hearing room today, they are bound by the terms of the agreement as stated on the record even though there is no subsequent signing affirming the terms, of settlement. However, we have discussed having the parties and counsel return later this morning to review the agreement, make any typographical corrections as necessary, and then affix their signatures affirming the terms of settlement as stated on the record. The Master will then prepare an order vacating his appointment and counsel can then file a praecpe transmitting the record to the Court requesting a final decree divorce. The parties were married on March 2, 2002. The complaint inadvertently indicated the date of marriage as May, 2, 2002. As previously noted, the parties separated 2 on April 22, 2006. They are the natural parents of two children; both children are in the custody of wife. Since the filing of the divorce complaint, which indicated there was one child born of the parties, a child was born on November 8, 2006, whose name is Madison. Ms. Adams. MS. ADAMS: The parties have agreed as follows: 1. On the second Saturday in June 2010, wife will go to the marital home and obtain her personal items which are currently in the marital home and which are further described on a list exchanged by the parties today. The list as referred to will be attached to the agreement as a joint exhibit of the parties. 2. The parties agree that husband will retain possession of the marital home. He recently received a notice from Upper Frankford Township that the property needs to be cleaned up. He has agreed that he will clean up the property by June 8, 2010. Husband will indemnify wife for any fines or other legal actions which are taken against the property as a result of the notice. Husband's attorney will prepare a letter or a statement and submit that to the Upper Frank,ford Township board of supervisors or their representative which will state that husband will be solely responsible for the clean up and for any fines or legal action which is taken against the property. 3. Regarding -the mortgage on the marital home, husband has been working with Hope Mortgage Company. He indicated that he needs to submit an income and profit and loss statement to them to further the refinancing on the property. Husband indicated that he would submit all documentation in ten (10) days. The parties agree that wife will relinquish her interest in the marital home and that there is essentially no equity in the marital home and husband may proceed with the refinancing and upon refinance wife will not be requesting any consideration or pay out for the home. 4. Husband's attorney has agreed to prepare a deed indicating that wife relinquishes all right, title and interest to the marital home which wife will promptly sign and which will be held in escrow by wife's attorney. The 3 parties will cooperate in moving the refinancing along and shall provide any documentation needed to the finance company. Husband will seek approval for the refinancing within ninety (90) days. Upon final refinancing, wife's attorney will release the deed and/or record the deed on behalf of the parties at the Recorder of Deeds. 5. Husband will be responsible for all costs and expenses relating to the refinance. Husband shall also pay off the amount due to HUD under claim No. 7-80720907-0 and shall indemnify wife for the payment of such claim which is in the amount of approximately $4,370.36. If the said refinance is not approved in ninety (90) days, the parties shall list the marital home for sale with a realtor or for sale privately immediately. However, if the financing is proceeding but not complete in ninety (90) days, the parties mutually agree to extend such time period. If the house is sold, upon sale, the part:-es shall divide equally all proceeds. However, if there is an amount due and owing as a result of the sale, husband shall be solely responsible for said debt. 6. Husband has agreed that he will be responsible for all utilities, costs, and expenses and anything incurred regarding the marital home. The parties will cooperate to transfer the electric bill into husband's name by June 8, 2010. The parties agree that all other utilities, if any, shall be transferred into husband's name by June 8. By June 8, husband will report to his attorney and to wife's attorney as to progress on payment made for the mortgage and any progress made regarding the refinancing and the parties shall, cooperate in any documentation required to promote the refinancing. 7. Husband is in possession of a 1994 Geo Prism which is currently located at the martial property. Within thirty (30) days the parties will transfer that title into husband's name alone. 8. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at thee request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or 4 4 advisable to carry into effect this mutual waiver and relinquishment: of all such interest, rights, and claims. THE MASTER: Mr. Glasser, have you been present during the statement of the agreement on the record? MR. GLASSER: Yes. THE MASTER: And do you have any questions about the agreement? MR. GLASSER: No. THE MASTER: And you are willing to accept this',as a final resolution of all claims between you and your wife in the divorce proceedings? MR. GLASSER: Yeah. The only question that I do have -- she is saying about the total refinancing, I don't know if this Hope, whether it is just refinancing or if it's modification on it. I will have to clarify that with them. THE MASTER: You understand that her goal is to have her obligation for any monies that are due on that property extinguished or removed. So however you want to characterize it, whatever is to happen, is that in order for this refinancing to occur the way it's understood to occur between the two of you is that she is to be relieved of any obligations. You understand that? MR. GLASSER: Yeah. MS. ADAMS: And that is to include the HUD 5 loan and if that cannot be rolled into -the modification or refinance and it's not paid, the agreement includes -- MS. ALEXANDER: That's very clear in the agreement. MS. to the agreement? MS. MS. MS. MS. stipulations? ADAMS: Okay. Kitty, have you listened GLASSER: Yes. ADAMS: Do you understand the agreement? GLASSER: Yes. ADAMS: Are you agreeing to your MS. GLASSER: Yes. MS. ADAMS: And you understand that this is a full and final resolution of all claims? MS. GLASSER: Absolutely. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend 6 to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: Jane A114x iT der Attorn for Plaintiff 4 ?Je Adams t orney for Defendant DATE: S? p David la serf XV y M. Glasser 7 -,- 1k...-- . -&U1 t un i:v, r 1 r :JwV 101V Jane, Hare is the revised list of Items still in the house. I have revised the list and removed items that are already in my possession. However the items remaining on this list are stil. at Dave's house and they are the things that I want out. These are the things that we need to include into the divorce settlement. Thanks for your help, Kitty M. Glasser Items that were mine going into the marriage Boxes of College school books Boxes with old snail that I had saved Boxes with books from High School that Includes year books Old typewriter Yazd sale items, boxes of stuffed animals, ceramics, ext. Items that were originally mine that I was planning to sell. Gifts to Me during Marriage Painting of a little girl that was purchased as a gift for m and I haven't been able to find. - Wooden Ceramic holder that is nailed to the wall in dining room was a gift from Dave to me, not for him to keep, Joint items that were purchased daring marriage and I want - Half of the paintings purchased during our honeymoon. - Copy of all pictures taken of Donavan that are still on film and have yet to be developed. - Copy of photos from Donavan's first birthday on CD, unless Dave's mother gave him her pictures of that day then I want the CD. Most of the baby toys in the attic had been gotten for Donavan that I want. This includes and toys given to Donavan from my family and friends. All things iti the attic that he finds as he's cleaning or when he moves, that belong to one, will be returned to rne. He knows what things are mine and what are his. EXHIBIT r M, DAVID E. GLASSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. KITTY M. GLASSER, Defendant No. 06 - 2954 Civil Term : IN DIVORCE CIVIL ACTION - LAW PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please accept this request to transmit the record, from Defendant, together with the following information to the Court for entry of a divorce Decree, as Plaintiff has failed to move forward with this matter and request a final Decree: 1. Grounds for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and Manner of the service of the Complaint: via first class mail, certified, return receipt requested; accepted May 24, 2006; acceptance of service filed by Plaintiff's attorney on or about May 30, 2006. 3. Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: By Plaintiff: May 21, 2010 By Defendant: May 21, 2010 4. Related claims pending: None; all were resolved by agreement at the Divorce Master's office; said agreement was signed and transcribed and is being filed contemporaneously with this Praecipe. 5. Date', Defendant's Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: May 21, 2010. 6. Date 'Plaintiff s Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: May 21, 2010. Date:( Ily submitted, J e Adams, Esquire Vp. No. 79465 7 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR DEFENDANT DAVID E. GLASSER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. KITTY M. GLASSER, NO. 06 - 2954 Civil Term. DIVORCE DECREE AND NOW, ,Zv(.r , W01y , it is ordered and decreed that DAVID E. GLASSER, plaintiff, and KITTY M. GLASSER, , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None; the parties' agreement, which was entered before the Divorce Master, shall be incorporated and not merged into this Decree. By the Court, Attest: J. Prothonotary it • a a r ID C'e`p` n?°' ?` -1 .4 4*40-? 44 dwt44" r 1 FiLED-OFFICE 05F THE PROTf4oNr)- 2011 FEB -9 AM 1!: 2P CUMBERLAHE) CoUWI-1,1 PENNSYLV Rd ?; DAVID E. GLASSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 06 - 2954 Civil Term KITTY M. GLASSER, : IN DIVORCE Defendant 4 ORDER AND NOW, this 94 day of ?a?? , 2011, a hearing regarding Defendant's Petition is scheduled for the 31,6't day of 7/wa t ? , 2011, at 9- %31J A.M.Ai6M in Courtroom No. of the Cumberland County Courthouse in Carlisle, Pennsylvania. By the Court: cc: Jane Alexander, Esquire /Jane Adams, Esquire ?,,pi,e 0((jecf DAVID E. GLASSER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA. V CIVIL ACTION - LAW 2006-2954 CIVIL TERM IN DIVORCE KITTY M. GLASSER, Defendant IN RE: APPEARANCE OF PLAINTIFF'S ATTORNEY WITHDRAWN ORDER OF COURT AND NOW, this 31st day of March, 2011, on motion of the captioned plaintiff, David E. Glasser, the appearance of Jane Alexander, Esquire, as his counsel is withdrawn. By the Court, Jane Alexander, Esquire For Plaintiff ? Jane Adams, Esquire For Defendant V :bg DAand E. Gia.saer Kevi A. Hess, P.J. C: o ?? d cn+" Maile ? Rt ?© Cop, / 1 Z:0a ` DAVID E. GLASSER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA. V CIVIL ACTION - LAW C _C 2006-2954 CIVIL TERM rnW = =.n IN DIVORCE =rn v rn? KITTY M. GLASSER, CAT-- ?C3 Defendant - > .?- Q r - <d IN RE: PETITION TO ENFORCE MARRIAGE SETTLEMENT A GRA?lk -n ORDER OF COURT D X- AND NOW, this 31st day of March, 2011, in accor danc e with the agreement of the parties, as announced in open court and in their presence, it is ordered and directed: 1. The parties jointly own a property located at 711 Bloserville Road, Newville, Pennsylvania. The parties shall list the property for sale within seven days of today's date with Kimberly Dunbar or a licensed real estate agent of their choosing. 2. The husband will make any recommended repairs requested by the realtor within thirty days of lasting at his own expense. 3. The wife shall promptly inform husband of any actions to be taken regarding the property in order to list and sell the property. 4. The wife is granted a limited power of attorney to solely list, prepare and sell the property or take any other action necessary to sell the property. 5. If husband fails to prepare the property for sale pursuant to the realtor's request, the wife may request that he vacate the property in fourteen days, and the husband shall vacate the property. 6. The husband shall reimburse the wife for the amount of $2,279.00, which was seized by the IRS to satisfy -1-041 GLASSER V. GLASSER the HUD loan associated with the property and pursuant to the marriage settlement agreement entered before the divorce master. 7. The husband shall return any of wife's personal possessions which he finds in the home when he vacates the property. By the Court, D ,,Id E. G Lasser ,.,/Jane Alexander, Esquire For Plaintiff Jane Adams, Esquire For Defendant =:?? A44r, Kevin Hess, P.J. M? Orb bg DAVID E. GLASSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVAN,4 c V. : No. 06 - 2954 Civil Term KITTY M. GLASSER, : IN DIVORCE Defendant -v AFFIDAVIT OF SERVICE 77 I, Jane Adams, Esquire, do hereby certify that on June 3, 2011, 1 served a true and correct copy of Defendant's PETITION FOR CONTEMPT in the above-captioned matter upon the following individual(s) by certified mail, restricted, return receipt requested, addressed as follows: David Glasser 711 Bloserville Road Newville, Pa. 17241 PLAINTIFF/RESPONDENT ¦ 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: ?.u? cA G1a,aeerv NEw`1. \?? Q A A. D. Is delivery ad If YES, enter f4 ? Agent dressee Delivery N 1? is - PS 3. ? Express Mail 13 Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Numbw- (rians W firom sendce label) 7 9 0080 0001 8043 514 8 J rorm its] 1, February 2004 Domestic Return Receipt Respectfully Submitted: Date: 0 A OM)&, tJe ams, Esquire 79465 South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 102595-02-M-1540 DAVID E. GLASSER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. -Y _`- r7j,Co r rn ? i 77 i? KITTY M. GLASSER, IN DIVORCE .2 .T);,€ Defendant NO. 06-2954 CIVIL TERM r") C? IN RE: PETITION FOR CONTEMPT c'D .` , ORDER OF COURT _ AND NOW, this 24th day of June, 2011, in accordance with the agreement of the parties as announced in open court and in their presence, IT IS ORDERED AND DIRECTED THAT: 1. Husband will vacate the marital property located at 711 Bloserville Road, Newville, Pennsylvania, on July 1st, 2011, by 6:00 p.m. At that time husband will relinquish all keys to wife and to the realtor. 2. Husband will have all clutter and debris cleared by July 1st, 2011, at 6:00 p.m. 3. Realtor will visit the property on July 1st at 6:00 p.m. and take pictures. If the property is not cleaned up in a satisfactory manner in which it can be listed for sale as is, she will engage a professional cleaning service to clean the property and husband shall be responsible to pay any costs associated with the clean up. 4. Wife's brother-in-law may clear the fallen tree which is on the property and keep any firewood due to clearing the tree. 5. Husband shall pay wife's attorney's fees in the amount of $750.00 within six months. 6. Husband will leave wife's personal possessions in the home for her to collect on July 1st, and he shall place her possessions in a box in the living room. By the Court, Kevin ,Al. Hess, P.J. 7 ./Duane P. Stone, Esquire For the Plaintiff WLd Jane Adams, Esquire COPS 11 For the Defendant t°/a7' 0166 :lfh