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HomeMy WebLinkAbout06-3112 HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17019 (717) 245-6090 ATTORNEY FOR PLAINTIFF NANCY L. PATIL, V. : IN THE COURT OF C MMON PLEAS OF Plaintiff : CUMBERLAND COU TY, PENNSYLVANIA CIVIL ACTION - LAW, NO. 2006 - 3/11 CIV L TERM ANNARAO 0. PATIL, . Defendant :IN DIVORCE NOTICE You have been sued in court. If you wish to defend against following pages, you must take prompt action. You are wam( the case may proceed without you and a decree in divor( entered against you by the court. A judgment may also be er other claim or relief requested in these papers by the plaintiff. property or other rights important to you, including custody or When the ground for divorce is indignities or irretrievable you may request marriage counseling. A list of marriage I Office of the Prothonotary, Cumberland County Courth( 17013. he claims set forth in the 1 that if you fail to do so, s or annulment may be :e red against you for any You may lose money or sitation of your children. :down of the marriage, slors is available in the Carlisle, Pennsylvania IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORC OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF HEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO R TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Ass 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 0I NANCY L. PATIL, Plaintiff V. ANNARAO G. PATIL, Defendant : IN THE COURT OF : CUMBERLAND CO CIVIL ACTION - LA NO. 2006 - -311 ZC : IN DIVORCE MON PLEAS OF , PENNSYLVANIA TERM COMPLAINT IN DIVORCE UND R SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, complaint in divorce against the defendant, representing as fc 1. The plaintiff is NANCY L. PATIL, an adult individual Lane, Enola, Cumberland County, Pennsylvania 17025. 2. The defendant is ANNARAO G. PATIL, an adult Aspen Lane, Enola, Cumberland County, Pennsylvania 17025. 3. The parties have been residents of the Commonwealth six months prior to the filing of this action in divorce. 4. The parties were married on January 11, 1963 in Reno, 5. Pursuant to the Divorce Code, Section 3301(c), the plai upon which this action is based that the marriage between the and files this at 5785 Aspen residing at 5785 Pennsylvania at least avers as the grounds ties is irretrievably broken. 6. The plaintiff avers that she has been advised of the av ji'ability of counseling and that he has the right to request that the court require the parti s to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the Iarriage between the two parties. I verify that the facts contained herein are true and correct. I u derstand that false statements herein made are subject to the penalties of 18 Pa. . S. Section 4904 relating to unsworn falsification to authorities. May 30, 2006 NAN Y L. P It, Pla ntiff HAROLD S. IRWIN, II Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvani 17013 (717) 243-6090 Supreme Court ID 29920 NANCY L. PATIL, : IN THE COURT OF : CUMBERLAND CO] : CIVIL ACTION - LA NO. 2006 - C WON PLEAS OF , PENNSYLVANIA Plaintiff V. ANNARAO O. PATIL, Defendant P : IN DIVORCE The plaintiff, being duly sworn according to law, deposes and 1. I have been advised of the availability of marriage TERM and understand that I may request that the court require that my spouse and I (participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon reque t. 3. Being so advised, I do not request that the court requirethat my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 1 1 Pa. C.S. Section 4904 relating to unswom falsification to authorities. May 30, 2006 A Y L. N Y -e ? r n r '11 O -c NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS OF PlalntMl : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 2006 - 3112 CIVIL TERM ANNARAO 6. PATIL, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(1) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on June 10, 2006, by certified mail addressed to the defendant at 5785 Aspen Lane, Enola, PA 17025, certified mail No. 7005 1820 0002 4619 1965. 3. A copy of the sender's and return receipts are attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. „ June 12, 2006 Harold S. Irwin, III Attorney for plaintiff 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court ID No. 29920 Ln 0 CERTIFIED MAIL,,., R ECEIPT Q- (Domestic Only: Coverage Provided) G' r9 For delivery information OFFI visit our webs CIA ite at www.usps.com L USE .a Postage $ ` 65 C3 certified Fee y o C3 Return Receipt Fee Postma* (Endorsement Required) l . $ 1& Here O ru Restricted Delivery Fee (Endorsement Required) 3 .5 r? Totes Postage a Fees $ $, 3 uT 0 Sent To O 171- 3rreet Apt No.; -^-°------ or PO Box No. n G City, State, 2IRfd ^ r i 0 PS Form 3800. June 2002 See Reverse for nstru(;tjojjs ¦ 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 hack of the mailpiece, •• or on the front if space permits. 1 • Artlcl4 Addressed to: ANNARAO G PATIL 5785 ASPEN LN s'I) ENOLA PA 17025 01 Vor dd 1, A. si X :1? - o Agent 0 Addressee S. Received by (Pdntedn wW) C. Date of DW wy D. Is ddvery address dxleent from him 1? O Yes If YES, enter dexvery addrees below: 899 Rg `RAC?' Ar...._ -- 3. Vw1w Type • Cedried Max 0 6rprses Mau C1 Registered o Ream Retrelpt for Merohwwse O Insured Mall ? C.O.D. 4. RwbLted Delivery? (Extra Fee) 2. Artldfor ftmr service 7205 1820 0002 4619 1965 r- 11 - PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1640 i EXHIBIT nAYO w__ -r2; n ??? N ,. ',' ? , =, d ;', S> ? .. :' `? -?C ?V --: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION L. PATIL, Case No.: 2006-3112 Plaintiff, V. G. PATIL, Defendant. PRAECIPE FOR ENTRY OF APPEARANCE To t} e Prothonotary: Please enter the appearance of the Law Offices of Peter J. Russo, P.C. and Scott A. S?ein, Esquire, as counsel for the Defendant, Annarao G. Patil, in the above captioned Respectfully submitted, LAW OFFICES O P T " J. RUSSO, P.C. Peter J. Russo, Esquire Attorney I.D. No. 72897 Scott A Stein, Esquire Attorney I.D. No. 81738 Elizabeth J. Saylor, Esquire Attorney I.D. No. 200139 3800 Market Street Camp Hill, PA 17011 717-591-1755 IC-).3 -0.6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION L. PATIL, Case No.: 2006-3112 Plaintiff, PACSES Case No.: 276108313 vi. G. PATIL, Defendant. CERTIFICATE OF SERVICE the 64 I, Janet E. Bush, hereby certify that I served a true and correct copy of the within 'IPE FOR ENTRY OF APPEARANCE, by first class mail, postage prepaid, on S. Irwin, III, Esquire h Pitt Street ,, PA 17013 J yet E. Bush, Paralegal )-7?F_ db (y-c- rya r? ° 7 ?7 ?" _i ?.' ri?-r N ?'?, ?? G-, ? -?- `,• ` Sr. z7 :? y NANCY L. PATIL VS. ANNARAO G. PATIL Defendant : IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW NO. 2006 - 3112 CIVIL TERM : IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE Please withdraw the appearance of the undersigned as attorney for Annarao G. Patil in the above-captioned Divorce Action. ?f- Date: 7- By: Scott Stein, Esquire Law Offices of Peter Russo 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorney I.D. # ENTRY OF APPEARANCE Please enter the appearance of the undersigned as attorney for Annarao G. Patil, Defendant, in the above-captioned Divorce Action. Date: -7 ? /O <o 06511-001/104434 By: r')__? ?2 4 Carl G. Wass, Es*re Attorney for Defendant Caldwell & Kearns 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 - Phone Sup. Ct. I.D. No. 07268 ?° .... ? , } ?tl. t. _ Y. ..;? HAROLD S. IRWIN, 111, ESQ ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2006 - 3112 CIVIL TERM ANNARAO G. PATIL, Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Daniel R. Beecher, Defendant, moves the court to appoint a master with respect to the following claims: (X) Divorce (X) Distribution of Property ( } Annulment (X) Support (X) Alimony (X) Counsel Fees ( ) Alimony Pendente Lite (X) Costs and Expenses and in support of the motion states: (1) Discovery is not complete as to the claim(s) for which the appointment of the master is requested. (2) The plaintiff has appeared in the action by her attorney, Mark Emery, Esquire. (3) The statutory grounds for divorce as stated by plaintiff are Section 3301 (c). (4) Delete the inapplicable paragraph(s): (a) The action is contested. (b) An agreement has been reached with respect to the above claims for: NIA (c) The action is contested with respect to the following claim(s): ALL (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: Defendant has responded to plaintiffs discovery requests, but has received no discovery responses from plaintiff, who inists that defendant's responses were incomplete and will not provide anything to defendant at this e. OCTOBER 12, 2006 HAROLD S. IRWIN, III Attorney for Plaintiff ORDER APPOINTING MASTER NOW, this day of , 2006, E. ROBERT ELICKER, II, ESQUIRE, is appointed master with respect to the following claims: By the Court, J. CT HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2006 - 3112 CIVIL TERM ANNARAO G. PATIL, Defendant : 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 prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in 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, Carlisle, Pennsylvania 17013. 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, Pennsylvania 17013 717-249-3166 NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2006 - 3112 CIVIL TERM ANNARAO G. PATIL, Defendant : IN DIVORCE AMENDED COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this amended complaint in divorce against the defendant, representing as follows: 1. The plaintiff is NANCY L. PATIL, an adult individual residing at 5785 Aspen Lane, Enola, Cumberland County, Pennsylvania 17025. 2. The defendant is ANNARAO G. PATIL, an adult individual residing at 5785 Aspen Lane, Enola, Cumberland County, Pennsylvania 17025. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on January 11, 1963 in Reno, Nevada. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. COUNT 11 Alimony Pendente Lite, Attorney Fees, Costs and Expenses 7. Plaintiff incorporates by reference the averments contained in paragraphs one through six of her complaint. 8. By reason of this action, plaintiff will be put to considerable expenses in the preparation of her case, in the employment of counsel and in the payment of costs. 9. The plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation and unable to appropriately maintain herself during the pendency of this action. 10. The plaintiff's income is not sufficient to provide for her reasonable needs and pay her attorney's fees and the costs of this litigation. 11. The defendant does have adequate earnings and assets to provide support for the plaintiff and to pay her counsel fees and expenses. COUNT III Alimony 12. Plaintiff incorporates by reference the averments contained in paragraphs one through eleven above. 13. Plaintiff lacks sufficient property to provide for her reasonable needs. 14. Plaintiff is unable to sufficiently support herself through appropriate employment. 15. Defendant has sufficient income and assets to proive continuing support for the plaintiff. COUNT III Equitable Distribution 16. Plaintiff incorporates by reference the averments contained in paragraphs one through fifteen of her complaint. 17. During the parties marriage they accumulated substantial personal and real property assets over which the defendant maintain total control and which are subject to equitable distribution. WHEREFORE, the defendant requests the Court to enter a Decree: A. Dissolving the marriage between the parties; B. Ordering payment of alimony pendente lite, counsel fees and expenses as the Court deems just and reasonable; C. Awarding alimony as the Court deems just and reasonable; D. Equitably distributing all assets and liabilities of the marriage; E. Ordering plaintiff to maintain health insurance coverage on defendant; and F. For such further relief as the Court may deem equitable and just. October 12, 2006 HAROLD S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 Verification I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. October 12, 2006 NA CY L. 7 &TI IL, Plaintiff ?.? ?!`-? ?.?l ?. 0' G ? ? 7 ?' -. <a ?? ? C: ?? ' , `??' ?': ?' C'`? , ?Cti . ?, ?_y, .` ?? :..r ' ; ? L ? . ; ? ? OCT 13 2006 HAROLD S. IRWIN, III, ESQ ATTORNEY 10 NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF NANCY L. PATIL, V. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2006 - 3112 CIVIL TERM ANNARAO G. PATIL, Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Daniel R. Beecher, Defendant, moves the court to appoint a master with respect to the following claims: (X) Divorce (X) Distribution of Property ( ) Annulment (X) Support (X) Alimony (X) Counsel Fees ( ) Alimony Pendente Lite (X) Costs and Expenses and in support of the motion states: (1) Discovery is not complete as to the claim(s) for which the appointment of the master is requested. (2) The plaintiff has appeared in the action by her attorney, Mark Emery, Esquire. (3) The statutory grounds for divorce as stated by plaintiff are Section 3301 (c). (4) Delete the inapplicable paragraph(s): (a) The action is contested. (b) An agreement has been reached with respect to the above claims for: N/A (c) The action is contested with respect to the following claim(s): ALL (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: Defendant has responded to plaintiffs discovery requests, but has received no discovery responses from plaintiff, who inists that defendant's responses were incomplete and will not provide anything to defendant at this e. OCTOBER 12, 2006 J HAROLD S. IRWIN, 111 Attorney for Plaintiff ORDER APPOINTING MASTER NOW, this IC16 day of ©t??. 2006, E. ROBERT ELICKER, II, ESQUIRE, is appointed master with respect to the following claims: o B t Court, )b, 1 CGLI J. 0 A ?- Q fuX o crt c t! t © N l~ f' 1 t? ` Um T? r.r f - " A .. Cam: G - - NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff no CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2006 - 5772 CIVIL TERM ANNARAO 0. PATIL, Dahndant : IN DIVORCE ACCEPTANCE OF SERVICE I, CARL G. WASS, ESQUIRE, attorney for the defendant in this divorce action, hereby certify that the defendant received a certified copy of the complaint in divorce on or about June 1, 2006, by certified mail addressed to him at 5785 Aspen Lane, Enola, PA 17025, certified mail receipt number 7005 1820 0002 4619 1903 (copy attached). I verify that the statements made in this acceptance of service 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. November l , 2006 'Q'- %'? ? L a-A--A CARL G. WAS Attorney for Defendant C7 ? C. ;J r t ? .... '"-"x. "?' - ? { _: ._ ? T ?'? _?..D ?, - - _ _,.. _ , -= - +" . 4^?J 7 ?_5? 7 -t; ?; HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 " SOUTH PITT STREET CARLISLE PA 17013 (717) 24341050 ATTORNEY FOR PLAINTIFF NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS OF PlalntHf : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2006 - 3112 CIVIL TERM ANNARAO 0. PATIL, : Dahndant : 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 prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in 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, Carlisle, Pennsylvania 17013. 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, Pennsylvania 17013 717-249-3166 NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2006 - 5712 CIVIL TERM ANNARAO 0. PATIL, Defendant : IN DIVORCE SECOND AMENDED COMPLAINT IN DIVORCE UNDER ?TIONS 3301(c) 3301 A 6 LCI AND OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this second amended complaint in divorce against the defendant, representing as follows: 1. The plaintiff is NANCY L. PATIL, an adult individual residing at 700 Tanglewood Road, Apartment 2, Muncy, Lycoming County, Pennsylvania 17756-8255. 2. The defendant is ANNARAO G. PATIL, an adult individual residing at 5785 Aspen Lane, Enola, Cumberland County, Pennsylvania 17025. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on January 11, 1963 in Reno, Nevada. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. In addition, pursuant to the Divorce Code, Section 3301(a)(6)(c), the plaintiff avers as a ground upon which this action is based that the plaintiff is the injured spouse and that the defendant has offered such indignities to her as to render her condition intolerable and life burdensome. 7. The plaintiff avers that she has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. COUNT 11 Alimony Pendente Lite, Attorney Fees, Costs and Expenses 8. Plaintiff incorporates by reference the averments contained in paragraphs one through seven of her complaint. 9. By reason of this action, plaintiff will be put to considerable expenses in the preparation of her case, in the employment of counsel and in the payment of costs. 10. The plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation and unable to appropriately maintain herself during the pendency of this action. 11. The plaintiff's income is not sufficient to provide for her reasonable needs and pay her attorney's fees and the costs of this litigation. 12. The defendant does have adequate earnings and assets to provide support for the plaintiff and to pay her counsel fees and expenses. COUNT III Alimony 13. Plaintiff incorporates by reference the averments contained in paragraphs one through twelve above. 14. Plaintiff lacks sufficient property to provide for her reasonable needs. 15. Plaintiff is unable to sufficiently support herself through appropriate employment. 16. Defendant has sufficient income and assets to provide continuing support for the plaintiff. COUNT 111 Equitable Distribution 17. Plaintiff incorporates by reference the averments contained in paragraphs one through sixteen of her complaint. 18. During the parties marriage they accumulated substantial personal and real property assets over which the defendant maintain total control and which are subject to equitable distribution. WHEREFORE, the defendant requests the Court to enter a Decree: A. Dissolving the marriage between the parties; B. Ordering payment of alimony pendente lite, counsel fees and expenses as the Court deems just and reasonable; C. Awarding alimony as the Court deems just and reasonable; D. Equitably distributing all assets and liabilities of the marriage; E. Ordering plaintiff to maintain health insurance coverage on defendant; and F. For such further relief as the Court may deem equitable and just. November L7, 2006 HAROLD S. IRWIN, II Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 0 VERIFICATION I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. November, 2006 )"'-'? &&:Z? , N CY L. TIL, Plaintiff ? ?i -,k i 11 Carl G. Wass, Esquire Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 Attorney for Defendant Annarao G. Patril NANCY L. PATIL, vs. ANNARAO G. PATIL, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 - 3112 CIVIL TERM CIVIL ACTION LAW IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF SAID COURT: Pursuant to Pa.R.C.P. 1920.21.(a), please enter a Rule, as of course, upon Plaintiff, Nancy L. Patil, to file a, within twenty (20) days after service, Bill of Particulars pertaining to her claim of Indignities as a grounds for divorce, pursuant to Divorce Code Section 3301(a)(6)(c), or suffer non pros as provided in Pa.R.C.P. 1920.21(b). Respectfully submitted: Date: ?_ l Z O d ?a 4A.A Carl G. Wass, Es re Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 Attorney for Defendant Annarao G. Patil NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. ANNARAO G. PATIL, Defendant NO. 2006 - 3112 CIVIL TERM CIVIL ACTION LAW IN DIVORCE RULE TO FILE BILL OF PARTICULARS TO: NANCY L. PATIL, Plaintiff c/o: Harold S. Irwin,, III, Esquire 64 South Pitt Street Carlisle, PA 17013 Rule is hereby issued upon you directing that you file in the Office of the Prothonotary of Cumberland within twenty (20) days after your receipt of this Rule, A Bill of Particulars specifying with dates and a brief factual summary the basis upon which you intend to seek a divorce based upon claimed Indignities performed by the Defendant and directed toward you. A copy of the Bill of Particulars must be served upon the attorney for Defendant. Your failure to file the Bill of Particulars in a timely manner may result in the entry of a judgment of non-pros. Prothonotary, Cumberland County, Pennsylvania Date: I 6o(D By 1 CERTIFICATE OF SERVICE AND NOW, this day of , 2006, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Harold S. Irwin, 111, Esquire 64 South Pitt Street Carlisle, PA 17013 CALDWELL & KEARNS By c, C? t Jz `' sue . t NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2006 - 3112 CIVIL TERM ANNARAO G. PATIL, Defendant : IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about May 31, 2006. Service of the complaint was made upon defendant on or about June 1, 2006 by certified mail (see defendant's counsel's acceptance of service filed November 21, 2006). Plaintiff's second amended complaint was filed on November 27, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. February , 2007 CY L ATI I WAIVER O NOTICE OF INTENTION TO REQUEST E TRY OF A DIVORCE DECREE UNDER SEOTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 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. 3. 1 understand that I will not bl divorced until a divorce decree is entered by the Court and that a copy of the decree will be seat to me immediately after it is filed with the Prothonotary. I verify that the statements made in his affidavit 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. February Y-, 2007 NANCY L. P ? a ' tip *t 7 C 4 O Carl G. Wass, Esquire Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 Attorney for Defendant NANCY L. PATIL, Plaintiff vs. ANNARAO G. PATIL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006-3112 CIVIL TERM CIVIL ACTION LAW IN DIVORCE INCOME AND EXPENSE STATEMENT OF DEFENDANT ANNARAO G. PATIL Defendant Annarao G. Patil files the following Income and Expense Statement and verifies that the statements made herein are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Dated: Annarao G. Patil 1 INCOME: Employer: None/Retired Address: Type of Work: Payroll Number: Pay Period (Weekly, Biweekly, etc.): Gross Pa Per Pa Period: Itemized Payroll Deductions: Federal Withholding Social Security Local Wage Tax State Income Tax Retirement Savings Bonds Credit Union Life Insurance Health Insurance Other (specify) NET PAY PER PAY PERIOD: OTHER INCOME: WEEK MONTH YEAR Interest estimated average) 310.00 3,720.00 Dividends estimated average) 1,551.00 18,613.00 Pension estimated average) 2,000.00 24,000.00 Annuity Social Security 1,329.00 15,950.00 Rents Royalties Expense Account Gifts Unemployment Comp. Workmen's Comp. PaSERS 185.00 2,218.00 TOTAL INCOME 5,375.00 64,501.00 EXPENSES: WEEK MONTH YEAR HOME Mortgage/Rent Maintenance 65.00 780.00 Utilities Electric 93.67 1,124.00 Gas 120.67 1,448.00 Oil Telephone 43.25 519.00 Water 35.00 420.00 Sewer 40.00 480.00 EMPLOYMENT Public Transportation Lunch TAXES Real Estate 308.67 3,704.00 Personal Property 25.50 306.00 Income 416.67 5,000.00 INSURANCE Homeowners 48.58 583.00 Automobile 104.50 1,254.00 Life Accident Health 881.97 10,583.64 Other AUTOMOBILE Payments 82.17 986.00 Fuel 70.83 850.00 Repairs MEDICAL Doctor 80.00 960.00 Dentist 50.83 610.00 Orthodontist Hospital 54.17 650.00 Medicine 68.33 820.00 Special Needs (glasses, braces, orthopedic devices) 58.33 700.00 EXPENSES: WEEK MONTH YEAR EDUCATION Private School Parochial School College Religious PERSONAL Clothing 65.00 780.00 Food 318.88 3,820.00 Barber 20.00 240.00 CREDIT PAYMENTS Credit Card 6.25 75.00 Charge Account Memberships 15.00 180.00 LOANS Interest on Invest. Margin 121.58 1,459.00 MISCELLANEOUS Household Help 240.00 2,880.00 Child Care Pape rs/Books/Maazines 49.17 590.00 Entertainment 69.17 830.00 Pa TV 29.17 350.00 Vacation 1,223.33 14,680.00 Gifts 80.00 960.00 Le al Fees 291.67 3,500.00 Charitable Gifts 47.17 590.00 Spousal Support 1,255.00 15,060.00 TOTAL EXPENSES $ $6,479.53 $77,771.64 PROPERTY OWNED: Description Value Ownershi * H W J Checking Accounts 23,426.00 x Savings Accounts 861.00 x Credit Union Stocks/Bonds 1,586,704.00 x Real Estate 314,500.00 x Other TOTAL $1,925,496.00 INSURANCE: Company Policy No. Ownership* H W C Hospital Blue Cross Other Medical Blue Cross PEBTF 189-32-9890 x x Other Health/Accident Disability Income Dental Other-Life/Eye *H=Husband; W=Wife; J=Joint; C=Child 5131 C-? ? O k -71 P - 7 FT 1 r r N ?. r a CO "< NANCY L. PATIL, ANNARAO G. PATIL Plaintiff vs. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 2006-3112 CIVIL TERM CIVIL ACTION LAW IN DIVORCE INVENTORY AND APPRAISEMENT OF ANNARAO G. PATIL Defendant Annarao G. Patil files the following inventory and appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Defendant verifies that the statements made in this inventory and appraisement are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Dated:. Annarao G. Patil ASSETS OF PARTIES Defendant Annarao G. Patil., marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. If an item has been appraised, a copy of the appraisal report is attached. (x) 1. Real property (x) 2. Motor vehicles (x) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit (x) 5. Checking accounts, cash (x) 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes () 8. Trusts (x) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) () 10. Annuities () 11. Gifts () 12. Inheritances () 13. Patents, copyrights, inventions, royalties () 14. Personal property outside the home () 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) () 16. Employment termination benefits--severance pay, workman's compensation claim/award (x) 17. Profit sharing plans (x) 18. Pension plans (indicate employee contribution and date plan vests) (x) 19. Retirement plans, individual retirement accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) () 22. MilitaryN.A. benefits () 23. Education benefits () 24. Debts due, including loans, mortgages held (x) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute () 26. Other Q tf 4 cfl O cr 6? + + d w + O c0 N M 00 to r N N d to tD tC) O O N c`'t M O W O to c`? CO N O Q to O O r G C? M N O U u1 O O 0 a O asww O o a o Qow O ° ° O o p=O c c? 3 LL. O ° ° O o a o O a 0 ?z O o a -tea z ? a o ° .? o O a z O a o Q 0 W ° o 0 0 M G O O ??chMF? c0 w 0') CD r- *?- M O NO? O C M O cp O O C,4 r N P- co ?p i O Q C,4 0 U? U) N tf? Q O <( N O O N N U-) 00 t0ONrO ON N Q? QM Q Z Q co w to N O 00 07 ` Q ?t) Q tQ W p to O. U U-) O N 0. 0 O jF-t' r N ! - V F' U ? 74.0 M ? U N N `? a m u o 0 G O O w ?o o o G ° ?F a C) G G o ° p L] ? O L3 a >?/ ^ O o o c o °o o W p J a o G N o o ?, ? N od U") o ? v o O to 4 r,. ,? 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L LIABILITIES OF PARTIES Defendant Annarao G. Patil marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following page. SECURED () 1. Mortgages () 2. Judgments () 3. Liens () 4. Other secured liabilities UNSECURED () 5. Credit card balances () 6. Purchases () 7. Loan payments () 8. Notes payable () 9. Other unsecured liabilities CONTINGENT OR DEFERRED () 10. Contracts or Agreements () 11. Promissory notes () 12. Lawsuits () 13. Options () 14. Taxes () 15. Other contingent or deferred liabilities oW z O?pO 4ZI Q o W a a a. Q. o U Z W ) pI 0 v N W W ? W -`0 O 0 Z I` Z4-w o p W p `` co , J 4 OI C 0 N Q. p CO W N m U ~ 3 oI Z J_ 0 m ? 4 0 J N LL ly 0 00 N Q uj Z0 0 2. 0 a? O? ZU i? N r r a ? J o- m p N _? uj LL. O p W 14 d 0 tW,,,- ZI a ? to co O 0% ro d n U, t c-- 10 0 ITJ k© 0-0 H n p y r?3 H % 0 O ? 0 En Ixj © a ro ? ? - ?f lv? t H -Z Q C>. y y i. OR N 50 t r ly- CP U) W w #; x r,, -? co V 0 N nl -c> a .l p N o UN -J W o0 N p ? p - ,r- I uo Q -Z y -9 4 ,9 6'• cal LP N V CA OD O o W? tri o p n d cr xt ; vJ c Q tji (D Cl) ' r j°'N °o 'ZI 1-3 i ?.. ? z H G W H w. 1 .1% _ 1% w z ' Ef) O O ro tai ?t 0 0.. i y t7 w z .. s y H V t '? l w M ° d : 0 0 ° 0 [A N CAN W: H H c z r ? °O ?? N W T U.;A , i?- r?_ ? c? .? -: L„ ? c';t„._ `?' ... ?? tJ r_ _ ? ,.? ??; t`f1 . , W ? ...? t Carl G. Wass, Esquire Attorney I.D. No. 07268 CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 717-232-7661 Attorney for Defendant Annarao G. Patril NANCY L. PATIL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. ANNARAO G. PATIL, Defendant NO. 2006 - 3112 CIVIL TERM CIVIL ACTION LAW IN DIVORCE AFFIDAVIT OF CONSENT UNDER & 3301(C) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 31, 2006. 2. The Defendant has acknowledged by the certification of his attorney, filed of record, that he did receive on or about June 1, 2006 a copy of the Divorce Complaint by certify mail at his home address, being certified mail receipt number 7005 1820 0002 4619 1903. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 4. I consent to the entry of a final decree of divorce after service of the intention to request entry of the Decree. ti 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. Dated: 3 C7 e Pak Annarao G. Patil, D endant SS# 189-32-9890 t? ? _ ?? ?' ? ?-?t?.? --"? ;'Tl '? N .{ MARIA P. COGNETTI & ASSOCIATES KRISTOPHER T. SMULL, ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Defendant NANCY L. PATIL, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ANNARAO G. PATIL, Defendant : NO. 06-3112 CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Nancy L. Patil, Plaintiff in the above-captioned matter. ( r/ M COGNETTI & ASSOCIATES Date: b ? b I6 ? By: HER T. SMULL, ESQUIRE Attorney I.D. No. 69140 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff Kindly withdraw my appearance on Date: G. - \'3 _ 61-1 By: ancy L. Patil, HAROLD S. IRWIN, II ESQ Attorney I.D. No. Irwin Law Offices 64 S. Pitt Street Carlisle, PA 17013 Telephone No. (717)243-6090 the above-captioned matter. '?' ? d c- ? --? .. "'-'-' Try f!3 ? 'Iy?J ??_?j €?.. -..a?. .t L? .. ' ?' r .?? ,. ?a 1 'f .. .u ?, ?ti ,"?. MARIA P. COGNETTI & ASSOCIATES MARGARET M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Petitioner NANCY L. PATIL, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-3112 ANNARAO G. PATIL, : CIVIL ACTION - LAW Defendant/Respondent : IN DIVORCE PETITION FOR INJUNCTIVE RELIEF 1. Petitioner is Nancy L. Patil, an adult individual residing at 2001 Memorial Avenue, Apt. 18, Williamsport, Lycoming County, Pennsylvania 17701. 2. Respondent is Annarao G. Patil, an adult individual residing at 303 Sydney Street, Montoursville, Lycoming County, Pennsylvania 17754. 3. Petitioner filed a Complaint in Divorce on May 31, 2006. A true and correct copy of the Complaint in Divorce is attached hereto, made a part hereof, and marked Exhibit "A". 4. During the parties' marriage, and up to the date of their separation on or about May 30, 2006, they have acquired certain valuable real and personal property which are the subject of this Petition. To the best of Petitioner's knowledge and belief at this time, the assets are as follows: A. Real estate situated at 303 Sydney Street, Montoursville, Lycoming County, Pennsylvania, and the furnishings and decorations contained therein. B. Real estate in India. C. Vanguard - Individual Accounts. D. Ameritrade -Account No. 43821490. E. Fidelity Roth IRA - Account No. 140205176. F. Fidelity- Account No. Y03057339. G. Citibank NRI - India Account. H. A. G. Patil Associates Pension - for both husband and wife. I. A. G. Patil Associates - Profit-Sharing - Fidelity (for husband). J. Husband's Pennsylvania State Retirement Account. K. Vanguard Money Market - Account No. 0059. L. Vanguard IRA - Account No. 0059-09943979956. M. A. G. Patil Associates - Profit-Sharing - Vanguard (for wife). 5. Respondent has recently scheduled a trip to India where he owns a home, has bank accounts, a vehicle and many family members. 6. Respondent has recently ceased all cooperation in settling their property issues in this divorce. 7. Petitioner avers that Respondent has recently contacted the Hartford Insurance Company to cancel the homeowners insurance on the marital residence at 303 Sydney Street, Montoursville, Lycoming County, Pennsylvania 17754. (See Exhibit `B".) 8. Petitioner avers that Respondent has recently contacted the Hartford Insurance Company to cancel the automobile insurance on the only car he owns in the United States. 9. Petitioner avers that Respondent has dual citizenship in the United States and India. 10. Petitioner believes that Respondent will deplete, and/or convey, and/or transfer the parties' assets to India as the majority are in his name only. 11. Any transfers or other conversions of the marital assets would be to Petitioner's great detriment. 12. Petitioner has no adequate remedy at law. 13. Immediate and irreparable harm will occur to Petitioner if Respondent is not prohibited from transferring, dissipating or conveying the parties' marital assets. 14. This Court has full equity power and jurisdiction and may issue injunctions or other orders necessary to protect the interest of the parties and to effectuate the purposes of the Divorce Code of 1980, and may grant such other relief or remedy as equity and justice require. 23 P.S. §401(c). 15. In light of the above, Petitioner believes and avers there is a reasonable likelihood that Respondent may flee the jurisdiction of this Court and this country. WHEREFORE, Petitioner, Nancy L. Patil, requests this Honorable Court to: A. Enter an Order freezing the assets of the parties in order to restrain Respondent from, in any way, disposing, alienating, encumbering, dissipating, depleting, removing or hiding any such property in the future for the purpose of maintaining the status quo, pending final determination of the causes of action stated in the Complaint in Divorce and in any petitions or other pleadings filed by Respondent in the action of divorce, or otherwise; and B. To grant such other and further relief as is just and proper. Respectfully submitted, MARIA P. COGNETTI & ASSOCIATES Date: July 8, 2008 By: m . MARG RET M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Petitioner N a 0 C 7-1 HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 ; 64 SOUTH PITT STREET 1 TI CARLISLE PA 17013 (717) 243.6090 { ATTORNEY FOR PLAINTIFF NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. ANNARAO G. PATIL, Defendant : CIVIL ACTION - LAW : NO. 2006 - &/2-CIVIL TERM : 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 prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in 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, Carlisle, Pennsylvania 17013. 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, Pennsylvania 17013 717-249-3166 NANCY L. PATIL, V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2006 - CIVIL TERM Plaintiff ANNARAO G. PATIL, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is NANCY L. PATIL, an adult individual residing at 5785 Aspen Lane, Enola, Cumberland County, Pennsylvania 17025. 2. The defendant is ANNARAO G. PATIL, an adult individual residing at 5785 Aspen Lane, Enola, Cumberland County, Pennsylvania 17025. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on January 11, 1963 in Reno, Nevada. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. May 30, 2006 ?- NAN Y L. P ,Plaintiff A HAROLD S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 NANCY L. PATIL, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2006 - CIVIL TERM ANNARAO G. PATIL, Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. May 30, 2006 NA -CY L. P TIL, Plaintiff _ I Financial Auto & Home Insurance Program rte t ,E HARTFORD June 16, 2008 Coverage: Personal Umbrella Reference Number: 55PHE719198 Nancy Patil 303 Sydney St Montoursville, PA 17754-8337 Dear Nancy Patil, MCMIUM JUL 0 7 2008 BY: We are writing to you regarding your AARP Personal Umbrella Insurance quotation from The Hartford. Recently we received your request to cancel your Personal Umbrella Endorsement. For your protection, we need your signed authorization, indicating the date you wish the cancellation to be effective. Enclosed is a Policy Release Form for you to complete and return to us in the postage-paid envelope. Once received, we'll process your request promptly. We're sorry to lose you as a policyholder and hope you will consider The Hartford again in the future. If you have any questions, please call us at 1-800-423-4114. We are open Monday through Friday from 7 a.m. to 11 p.m., your time and Saturday from 8 a.m. to 6 p.m., Eastern Time. One of our Hartford representatives will be happy to assist you. Sincerely, Michael Concannon Executive Officer, The Hartford AARP Personal Umbrella Insurance Program This insurance program is underwritten by Hartford Fire Insurance Company and its affiliates, Hartford, CT. 7177289183\551111\0616\PA\11.045\JS\PLICE-1000 Annarao G & Nancy Patil 303 Sydney St AJ%R I Financial Montoursville, PA 17754-8337 Auto Insurance Program from HARTFORD Coverage: Personal Umbrella Policy Number: 55PHE719198 PERSONAL UMBRELLA ENDORSEMENT CANCELLATION REQUEST FORM To cancel your Personal Umbrella Endorsement, please complete, sign and return this form in the postage-paid envelope provided. Please cancel my policy, effective: Month/Day/Year Named Insured Signature Spouse/Co-Owner Signature Date Date VERIFICATION I, NANCY L. PATIL, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. NANCY IgEATiL DATE: -7-8-Q8 CERTIFICATE OF SERVICE I, Margaret M. Simok, Esquire, hereby certify that on ?, 2008, 1 served a true and correct copy of the foregoing Petition for Inj cti Relief at the address indicated below: Carl G. Wass, Esquire Caldwell & Kearns 3631 North Front Street Harrisburg, PA 17110 Service by: Personal service via hand delivery r/ Service by First Class, United States Mail, postage pre-paid, mailed at Camp Hill, Pennsylvania, addressed as indicated above Overnight delivery Service by placing a copy of the above document in counsel's box in the Office of the Prothonotary of County Facsimile service Certified/Registered Mail MARIA P. COGNETTI & ASSOCIATES Date: `7 / 3/0 ?r By: ill MARGA T M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Petitioner ? m m c r ' d-v ? r .. r t t a 10 ". MARLA P. COGNErn & Assocums Attorneys & Counselors at Law 210 Grandview Avenue, Suite 102 ? Camp Hill, PA 17011 Telephone (717) 909-40601 Fax (717) 909-4068 Email CognettiLaw@aol.com Maria P. Cognetti* Practice Limited to Matrimonial Law Attorney at Law *Fellow, American Academy of Matrimonial Lawyers Fellow, International Academy of Matrimonial Lawyers July 8, 2008 Curtis R. Long, Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: PATIL v PATIL Our File No. 391 Dear Mr. Long: Margaret M. Simok Attorney at Law Karen A. Sheriff Paralegal Please find enclosed an original and three (3) copies of a Petition for Injunctive Relief in the above case. Kindly file the original of record and time-stamp and return the copies to me in the enclosed, self-addressed, stamped envelope. Thank you for your assistance in this matter. Should you have any questions, please contact me. Very truly yours, Margar t M. Simok MMS/dlh Enclosures cc: Carl G. Wass, Esquire Nancy L. Patil -7 - 9 &&AW :??A &4- - ow? - 'JUL Y X 2008 i MARIA P. COGNETTI & ASSOCIATES MARGARET M. SIMOK, ESQUIRE Attorney I.D. No. 89633 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Petitioner NANCY L. PATIL, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. ANNARAO G. PATIL, Defendant/Respondent : NO. 06-3112 CIVIL ACTION - LAW IN DIVORCE ORDER AND` NOW, this day of , 2008, upon consideration of the within Petition, it is hereby ORDERED and DECREED that a preliminary injunction be issued. Until further Order of this Court, Respondent, Annarao G. Patil, is enjoined from disposing, w2$ l 6Z? transferring, encumbering, concealing, selling, removing or alienating any real and personal property ti owned by Petitioner or Respondent, individually, in co-ownership or in any other individual's or entity's name. Hearing on the continuation of the injunction is scheduled for the 61!k day of 2008, at 3 D o'clock A-.M., in Courtroom No. _J_ of the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. BY THE COURT, SSA(r) - () ?* ua:; - .?5 w Attu :ew 33141 - 80/'7//4 9 I :g wv 91 ?nr 8001 3H1 jo kAlj NANCY L. PATIL, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW ANNARAO G. PATIL, Defendant/Respondent NO. 06-3112 CIVIL TERM IN RE: PETITION FOR INJUNCTIVE RELIEF ORDER OF COURT AND NOW, this 6th day of October, 2008, upon consideration of the Petition for Injunctive Relief filed in the above-captioned matter by Plaintiff, and following a conference in chambers between counsel for the Plaintiff in the person of Margaret M. Simok, Esquire, and counsel for Defendant in the person of Carl G. Wass, Esquire, and pursuant to an agreement of counsel, the hearing scheduled for today's date on the Petition for Injunctive Relief is continued generally. In the event that neither counsel by motion requests a rescheduling of the hearing within 30 days, the Petition for Injunctive relief shall be deemed dismissed without further order of Court, and the preliminary injunction issued on July 14, 2008, shall be deemed dissolved without further Order of Court. By the Court, -"Margaret M. Simok, Esquire 210 Grandview Avenue Suite 102 Camp Hill, PA 17011 For Plain??tffiff/Petition--er t-Tt?,S' rnvtle rcL :mae l U?7?0 ? Carl G. Wass, Esquire 3631 N. Front Street Harrisburg-; PA 17110 For Defendant/Respondent IS Y r i t ? ??' ,,?a ? '?.,.5 ? ??yp l? l ?•i .. V ? "? ?? i `~ ??3V Mi9 i?V f ??aM.t?t?. ? ?? ?a ?} s .t NANCY L. PATIL, Plaintiff VS. ANNARAO G. PATIL, Defendant TO THE PROTHONOTARY: SIR: . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 06-3112 CIVIL ACTION-LAW IN DIVORCE PRAECIPE Please enter my appearance on behalf of Nancy L. Patil, Plaintiff above named. ANTHONY D. MIELE II Anthony D. Miele, Esquire I.D. #07553 Attorney for Plaintiff 322 Court Street Williamsport, PA 17701 (570) 327-4599 October 17, 2008. -? N °' r-?-, ,. --:..? ? -?. `^-i ?7`f =? d } .? ?t "7 ? _-^0 q ^^C NANCY L. PATIL, - Plaintiff VS. ANNARAO G. PATIL, . Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 3112 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this 6.n 'A day of CZA?L , 2008, on relation of the parties* in the above captioned proceedings that the parties have reconciled, and they no longer wish to continue with the divorce action, the appointment of the Master is vacated. BY T OURT, VC-11k4_1 Edgar B. Bayley P.J. cc: Maria P. Cognetti, Attorney for Plaintiff N ncy L. Patil, Plaintiff Attorney for Defendant Carl G. Wass, Annarao G. Patil, Defendant * See letter dated October 22, 2008, from Nancy L. Patil and Annarao G. Patil, a copy of which is attached. 12 iE LL I- cr% c.-- >-. CL- C ": Czn NANCY L. PATIL, Plaintiff VS. ANNARAO G. PATIL, Defendant TO THE PROTHONOTARY: SIR: . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 3112 CIVIL . CIVIL ACTION-LAW IN DIVORCE PRAECIPE Please discontinue the above captioned action in Divorce. ANTHONY D. MI LE Anthony D. Miele, Esquire I.D. #07553 Attorney for Plaintiff 322 Court Street Williamsport, PA 17701 (570) 327-4599 November 11, 2008. C r-a {?' C f? t? w .,,r iiiP'f7 -{? ? "?^ {_ N ?? .. .._g