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Home My WebLink About06-3457WALTERHOUSE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA No. G(a - 31S'7 i! r RISTOPHER WALTERHOUSE, : Civil Action - Law Defendant :In Divorce NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the rims set forth in the following pages, you must take prompt action. You are med that if you fail to do so, the case may proceed without you and a decree divorce or annulment may be entered against you by the Court. A judgment ay also be entered against you for any other claim or relief requested in these pers by the Plaintiff. You may lose money or property or other rights important you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage selors is available in the Office of the Prothonotary at the Cumberland ,ty Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF ROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF IVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO LAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF DU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR LEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU AN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 F A RR'& LINDSAY 26 West High Street Carlisle, PA Respectfully submitted, SAIDIS, FLOWER & LINDSAY By Marylo as, Esqui Supreme Court ID # 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff WALTERHOUSE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA OG • 3'F5? :No. rOPHER WALTERHOUSE, : Civil Action - Law Defendant :In Divorce COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE SAIDIS FLOWER& LENDS" 26 West High Street Carlisle, PA 1. The Plaintiff is Dawn Walterhouse, an adult individual residing at 8 Circle, Shippensburg, Cumberland County, Pennsylvania. 2. The Defendant is Christopher Walterhouse, an adult individual g at 1865 Douglas Drive, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in Commonwealth of Pennsylvania for at least six months immediately prior to filing of this Complaint. 4. The Plaintiff and Defendant were married on July 4, 1996, in Ft. iie, Washington County, Maryland. 5. There have been no prior actions of divorce or for annulment ,een the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that has the right to request that the court require the parties to participate in 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in with §3301(c) of the Pennsylvania Divorce Code. COUNT II EQUITABLE DISTRIBUTION 8. The averments in paragraphs 1 through 7 are incorporated hereto Is if fully set forth herein. 9. During their marriage, the parties have acquired certain property, personal and real. WHEREFORE, Plaintiff requests this Court to equitably divide the marital COUNT 1111 ATTORNEY'S FEES AND COSTS 10. The averments in paragraphs 1 through 9 are incorporated hereto if fully set forth herein. 11. Plaintiff is unable to sustain herself during the course of this or to pay the necessary and reasonable attorney's fees and reasonable and expenses. WHEREFORE, Plaintiff requests an award of counsel's fees and COUNT IV ADULTERY 12. The averments in paragraphs 1 through 11 are incorporated hereto SAIIID)IS,& s if fully set forth herein. ]LINDSAY 13. Plaintiff is the innocent and injured party, and Defendant has 26 Wes[ High Strea Cuiisie•PA mmitted adultery during the marital relationship of Plaintiff and Defendant, in of their marriage vows and of the laws of the Commonwealth. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in with the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Marylo atas, Esquire Attorne d. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff WEBS?& LINDSAY 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document are true and I understand that false statements herein are made subject to the of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. A" 11 WdA6 1 &2 (o?141o Dawn Walterhouse SAID FLOWER & LENDS" 26 West High $trmt Carlisle, PA I ? )? k -? -) N V !'7 L i .t a-. C._ C - V C X7 Oil --1 1C _ c ifT WALTERHOUSE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 3ys7 STOPHER WALTERHOUSE, :Civil Action- Law Defendant : In Divorce PETITION FOR SPECIAL RELIEF PURSUANT TO PA. R.C.P. 1920.43 AND NOW, comes Plaintiff, Dawn Walterhouse, by and through her Marylou Matas, Esquire, and the law firm of Saidis, Flower & Lindsay, files this Petition for Special Relief, and in support thereof avers as follows: 1. Petitioner is Dawn Walterhouse, the above named Plaintiff, and an adult individual residing at 8 James Circle, Shippensburg, Cumberland County, Pennsylvania. 2. Respondent is Christopher Walterhouse, the above named Defendant, and an adult individual residing at 1865 Douglas Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff filed a Complaint in Divorce on or about June 15, 2006, which included a request for Equitable Distribution of the parties' marital estate. F?RI '& LINDSAY 26 West High Street Carlisle, PA 4. The parties separated on or about May 1, 2006. 5. The parties own personal and real property, including real estate located at 8 James Circle, Shippensburg, Cumberland County, Pennsylvania; various vehicles; furnishings; financial accounts; investments and the like. 6. Each party is in possession of different items of marital property and is maintaining responsibility for various marital debts. 7. At the time of separation, Respondent removed the marital family computer, which holds the family's digital photos. 8. Since separation, Petitioner has requested that Respondent copy the photos or otherwise allow her to retrieve the photos. 9. Respondent has refused to do so, and has threatened to destroy the photos. 10. Respondent's latest threat came immediately following the child support conference in which the parties' participated on June 14, 2006, at which time it was recommended that Respondent pay approximately $700.00 per month to Petitioner for the child support of their son. 11. Immediately following the support conference, in the Domestic Relations building, Respondent requested, in counsel's presence, that Petitioner sign a check made out to the parties' names jointly for him to retain. 12. Petitioner suggested that she would agree to sign the check if Respondent would provide all of the photos. ]FLOWERIS & LENDS" 26 West High Street Carlisle, PA 13. Respondent refused to do, he said out of fear that Petitioner would dispose of other marital property in her possession. 14. Petitioner, through counsel, expressed to Respondent that she is willing to enter into a stipulation that provides for the prevention of the disposal of any marital property by either party pending equitable distribution; Respondent refused. 15. Respondent gave Petitioner the indication then that he may destroy the photos, if he had not done so already. 16. Because of Respondent's threats to destroy property and his refusal to enter into an agreement to protect the property, Petitioner believes that the entry of an Order to prevent Respondent from destroying, selling, transferring, or otherwise disposing of all marital property in his possession is the only way to protect the estate pending equitable distribution. WHEREFORE, Petitioner requests your Honorable Court to enter an Order on an emergency basis to prevent either party from destroying, selling, transferring, or otherwise disposing of all marital property in his or her possession. Respectfully submitted, SAIDIS, FLOWER & LINDSAY FLAVVER & LINDSAY ,muw 26 West High Street Carlisle, PA Malyl6"atas, Esquire AttorrtWd. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and I understand that false statements herein are made subject to the of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. \hu M Wa QUA Dawn Walterhouse SAIDIS FLOWM & LENDSM 26 West High Street Carlisle, PA r T 771 G? A. DAWN WALTERHOUSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHRISTOPHER WALTERHOUSE,: Defendant : NO. 06-3457 CIVIL TERM ORDER OF COURT AND NOW, this 7t' day of July, 2006, upon consideration of Plaintiff's Petition for Special Relief Pursuant to Pa. R.C.P. 1920.43, a hearing is scheduled for Monday, August 21, 2006, at 1:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED AND DIRECTED that pending said hearing, neither party shall destroy, sell, transfer, or otherwise dispose of any or all marital property in his or her possession. This specifically includes any or all digital photos, or computer- related items that either party may have in his or her possession. Marylou Matas, Esq. 26 West High Street Carlisle, PA 17013 Christopher Walterhouse 1865 Douglas Drive Carlisle, PA 17013 Defendant, pro Se :rc BY THE COURT, .* ?I i DAWN WALTERHOUSE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW CHRISTOPHER WALTERHOUSE,: Defendant : NO. 06-3457 CIVIL TERM ORDER OF COURT AND NOW, this 81h day of August, 2006, upon consideration of the attached letter from Plaintiff's counsel, Marylou Matas, Esq., Plaintiff's Petition for Special Relief is deemed withdrawn and the hearing scheduled for August 21, 2006, is cancelled. BY THE COURT, ,,Irlarylou Matas, Esq. 26 West High Street Carlisle, PA 17013 , .ehhristopher Walterhouse J 1865 Douglas Drive Carlisle, PA 17013 Defendant, pro Se :rc b nql -0+ VINVAIAsNN3d 8 1 : I I WV 6- SnV 400Z Curtis R. Long Prothonotary office of the Protbonotarp Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Lin -3 YS ~I CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573