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HomeMy WebLinkAbout06-4498 Wilmer L. Bitner aka Lee Bitner : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06- 4(g9,P CIVIL TERM Rosanna M. Bitner : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Wilmer L. Bitner aka Lee Bitner Plaintiff V. Rosanna M. Bitner Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06- 1/ Y9P CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Wilmer L. Bitner, an adult individual, currently residing at 801 Pear Street, Lemoyne, Cumberland County, Pennsylvania, 17043. 2. Defendant is Rosanna M. Bitner, an adult individual, currently residing at 52 Taylor Boulevard, Harrisburg, Dauphin County, Pennsylvania, 17103. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on May 9, 1998 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Respectfully Submitted TURO LAW OFFICES 7/7 d Date 28 South Pitt Strq%* Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of the Divorce Complaint, by depositing same in the United tates Mail, certified, return receipt requested, on the day ofd, 2006, from Carlisle, Pennsylvania, addressed as follows: 61 Rosanna M. Bitner 52 Taylor Boulevard Harrisburg, PA 17103 TURO LAW 28 South Pitt StreSSf/ Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. Z,?L&a7 R lie a, ? Date Wilmer L. Bitn r b w C ? -a c to O q ay a PROPERTY SETTLEMENT AGREEMENT This Agreement, made and entered into this S day of , between Rosanna Bitner, of 55 Taylor Blvd., Harrisbur Dauphin C unty, Pennsylvania, herein referred to as "Wife", and Lee Bitner of 1914 Sterrets Gap Avenue, Cumberland County, Pennsylvania, herein referred to as "Husband." WHEREAS, the parties hereto are now Wife and Husband, having been lawfully married to each other on May 9, 1998 in Cumberland County, Pennsylvania; WHEREAS, the parties hereto are now living separate and apart since July 25, 2005 and desire to enter into an Agreement respecting their property rights regardless of the actual separation or other character thereof and their other rights, including the Wife's right to support and maintenance; WHEREAS, both and each of the parties hereto have been advised of their legal rights and the implications of this Agreement and the legal consequences that may and will ensue from the execution hereof, and each has had the opportunity to consult with his or her own competent legal counsel independent of each other; WHEREAS, each party warrants, as part of the consideration of this Agreement, that each has fully and completely disclosed all information of a financial nature requested by the other, and that no information of such nature has been subject to distortion or in any manner being misrepresented; and WHEREAS, other than as set forth herein, Wife desires finally and forever to relinquish all of her rights to be supported by Husband and all of her rights of dower, rights as heir or surviving spouse or otherwise, actual, currently existing, or inchoate, in and to the real and personal property of the Husband, now owned by him or which in the future may be owned by him, and all rights to counsel fees, or expenses and, other than as set forth herein, Husband likewise wishes to relinquish all his rights of curtsey, rights as heir or surviving spouse or otherwise, actual and currently existing or inchoate in and to the real and personal estate of the Wife, currently owned by her or which she may own in the future; NOW THEREFORE, the parties hereto intending to be legally bound hereby do hereby mutually agree as follows: 1. Separation. Husband and Wife do hereby mutually agree and consent to live separate and apart and do further agree that it shall be lawful for the Husband and Wife at all times hereafter to live separate and apart from each other, and to reside, from time to time, at such place or places as they respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each other. 2. No Molestation, Harassment or Interference. Neither party shall molest, harass or interfere with the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any means whatsoever. 3. Mutual Power and Estate Waiver. Except as otherwise expressly set forth herein, in which event such express provision shall take precedence over this paragraph, the parties hereto intend that from and after the date of this Agreement, neither shall have any spouse's rights in property or estate of the other, and to that end both parties waive, relinquish and forbear the rights of dower of curtsey, rights to inherit, rights to claim or take the Husband or Wife's or family exemption or allowance, to be vested with letters of administration or letters testamentary, or to take against any will of the other, and each agrees with the other if either should die intestate, his or her share shall descend to vest in his or her heirs at law, personal representatives, and next of kin, excluding the other as though he or she had died a widow or widower. And each further agrees that should the other die testate, his or her property shall descend to and vest in those persons set forth in the other's Last Will and Testament as though the spouse so designated as beneficiary had predeceased the testator. The parties further agree that they may and can hereafter, as though married, without any joinder by him or her, sell, convey, transfer or encumber any and all real estate and personal property which either of them now or hereafter own or possess and further agree that the recording of this Agreement shall be conclusive evidence to all of his or her right to do 2 so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given be necessary, the right and the power to appoint one or more times any person or persons whom the Husband or Wife shall designate to be the attorney-in-fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or otherwise, to enable either party hereto to alienate his or her real personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waives any right of election contained in Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an equitable distribution or married property ordered by the Court subsequent to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that neither shall hereafter be under any legal obligations to support the other, pay any expenses for maintenance, funeral, burial, or otherwise for the other, and to that end each of the parties hereto does hereby waive any right to receive support, alimony, alimony pendente lite, counsel fees, expenses, or any type of financial assistance whatsoever from the other, except as otherwise expressly provided for herein. 4. Debt. Wife applied for and received the following credit cards without Husbands knowledge, authorization and agreement. Furthermore, to maintain Husband's ignorance about the credit cards provided to Wife, Wife secured a post office address for credit card statements which served to further deceive Husband as to the credit cards existence. : a. Capital One: 5178051815184229 b. Aspire Visa: 4331970850056173 c. Bank of America: 5447195200024105 d. Direct Merchants Bank: 5458000552891950 e. Chase Bank: 5417162281658124 f. Household Bank: 5404240001472227 g. Capital One: 5291151634658759 The parties agree that Wife shall be responsible for the above existing debts in full, and Husband shall be blameless as to the liability of the above credit cards. 3 5. Future Debts. The parties further agree that neither will incur any more future debts for which the other may be held liable, and if either party incurs a debt for which the other will be liable, that party incurring such debt will hold the other harmless from 6, any and all liability thereof. Personal Property. All Personal Property has been distributed as to the parties' satisfaction. 7J Divorce. The parties acknowledge that an action for divorce between them has been filed by Wife and is presently pending a divorce between them in the Court of Common Pleas of Cumberland County to the caption Wilmer L. Bitner, a/k/a Lee Bitner v. Rosanna M. Bitner, 2006-4498 Civil Term. The parties acknowledge their intention and agreement to proceed in said action to obtain a final decree in divorce by mutual consent on the grounds that their marriage is irretrievably broken, and to settle amicably and fully hereby all claims raised by either party in the divorce action. The parties acknowledged they have executed simultaneously herewith the necessary Affidavits of Consent for the entry of a final divorce decree in that action. Breach. In the event that either party breaches any provision of this Property Settlement Agreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 81 91 Enforcement. The parties agree that this marital settlement agreement or any part or parts hereof may be enforced in any Court of competent jurisdiction. Applicable Law and Execution. The parties hereto agree that this Marital Settlement Agreement shall be construed under the laws of the Commonwealth of 1Q Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. This document shall be executed as original and multiple copies. The Entire Agreement. The parties acknowledge and agree that this Marital Settlement Agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are not other 11 4 representatives, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. Additional Instruments. Each of the parties shall on demand or within a reasonable period thereafter, execute and deliver any and all other documents and do or cause to be done any other act or things that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs, and other expenses reasonably incurred as a result of such failure. 19 IN WITNESS WHEREOF, the parties have set their hands and seals this day and year first written above. WITNESSES Wilmer/L. Bitner a/k/a Lee R anna M. Bitner 5 t-?a l i ^? / - ?``? ? ? r i„? , ;=-? -,° -fit ? as 0 6 - -q-q .9 9> ¦ Complete items 1, 2, and 3. Also complete item 4 If Restricted Delhay Is desired. ¦ Print your name and address on the reverse so that we can retum the card to you. ¦ Attach this card to the hack of the mailpleos, or on the front if space permits. 1. Article Addressed to: ©?c,nc?. cam- i?r?ner A. B. Rbc olved :by (Prlnred Name) I C. Date of Delivery D. Is delivery addrees dirment from item 1? 0 Yes if YES, enter delivery address below: ? No 3. lype. Cereeed Mall cl epwas Mail ? R"Wered ? Return Recoo for Merchandise ? Insured Mall ? C.O.D. 4. ReaMcted Delivery? (Extra Fee) ? Yeas ? Agent 2. Article Number (!Fenster from *Anl t o lebaj IJ?` J V PS Form 3811, Fybnwy woo Dat sWe FWa n RaoW 102595-0244-15,60' ?' ? ...? ?C i"' ? ,: f??=? ? - ?' ?- "'?-! __ .? ? `n? ? sv'' "; ?„ ` ? ? C, ? ° .. ..? ?~?,. Wilmer L. Bitner aka Lee Bitner Plaintiff v. Rosanna M. Bitner Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4498 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 7, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. D C -57 .4. I k cri E Wilmer L. Bitner aka Lee Bitner Plaintiff V. Rosanna M. Bitner Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4498 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER -4 3301 (c) OF THE DIVORCE CODE 1. 1 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 be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. Z/c2z? D e C'? ? C3 o 'r! ?.,.. ? ?'' ? -? _z? ? - '... r4 -r? L- _? = mj ? .. . ? ?. .. Wilmer L. Bitner aka Lee Bitner Plaintiff V. Rosanna M. Bitner Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4498 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 7, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 Wilmer L. Bitner Cam` --? .? lv A + - .a ri7j Wilmer L. Bitner aka Lee Bitner Plaintiff V. Rosanna M. Bitner Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4498 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $ 3301(c) OF THE DIVORCE CODE 1. 1 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 be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. -2 1A / 14 7 Date 4?d X?Lz-? ?q Wilmer L. itner ?y f 1 -bc rrl f3'? Wilmer L. Bitner aka Lee Bitner : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-4498 CIVIL TERM Rosanna M. Bitner : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD I TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under § (3301(c)) of the Divorce Code. 2. Date and manner of service of the complaint: Certified, Returned Receipt I mail delivered on or about August 10, 2006. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the I Divorce Code. 4. By Plaintiff: February 2, 2007 By Defendant: January 26, 2007 Related claims pending: None. Date the Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: By Plaintiff: February 2, 2007 By Defendant: February 2, 2007 alen R. Wa e Attorney for efendant I T1 'F F?I % t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. 4 Wilmer L. Bitner a/k/a Lee Bitner Plaintiff No. 06-4498 VERSUS Rosanna M. Bit Defendant DECREE IN DIVORCE AND NOW, 9007 , IT IS ORDERED AND DECREED THAT Wilmer L. Bitner a/k/a Lee Bitner , PLAINTIFF, AND Rosanna M. Bitner DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; Separation and Property Settlement Agreement is incorporated herein but not merged in the Divorce Decree. BY THE COURT: 1? ATTES J. i PROTHONOTARY ? ? ??v?tr d C4 . Cl ' L° lv•£t'& Wilmer L. Bitner aka Lee Bitner : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-4498 CIVIL TERM Rosanna M. Bitner : CIVIL ACTION - LAW Defendant/Respondent 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 will proceed without you and an adverse order may 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Wilmer L. Bitner aka Lee Bitner Plaintiff/Petitioner V. Rosanna M. Bitner Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-4498 CIVIL TERM : CIVIL ACTION - LAW PETITION FOR CONTEMPT AND NOW, comes Plaintiff/Petitioner Lee Bitner, by and through his attorney, Galen R. Waltz, Esquire, and requests the honorable court find the defendant in contempt of this court's February 9, 2007 Decree in Divorce that incorporated the Property Settlement Agreement: 1. The Plaintiff/Petitioner is Lee Bitner, an adult individual, currently residing at 1914 Sterretts Gap Ave., Carlisle, Pennsyvlanvia. 17013. 2. Defendant/Respondent is Rosanna M. Bitner, an adult individual currently residing at 52 Taylor Blvd., Harrisburg, Pennsylvania, 17103. 3. The Decree in Divorce was issued by the Honorable Kevin A. Hess on February 9, 2007 (Exhibit 1 attached hereto and incorporated herein as if fully set forth) and contained a paragraph ordering that the "Separation and Property Settlement Agreement is incorporated herein but not merged in the divorce decree" 4. The property settlement agreement was executed on January 26, 2007 and recorded in the office of the Prothonotary on February 8, 2007. (Exhibit 2 attached hereto and incorporated herein as if fully set forth). 5. Paragraph 4 of the property settlement details the wife's fraudulent use of the husband's name to receive seven (7) credit cards without his knowledge or consent... Wife applied for and received the following credit cards without Husband's knowledge, authorization and agreement. Furthermore, to maintain Husband's ignorance about the credit cards provided to Wife, Wife secured a post office address for credit card statements which served to further deceive Husband as to the credit cards existence. 6. The wife acknowledges the debt, her deceptive acts and agreed in Paragraph 4 of the property settlement that... Wife shall be responsible for the above existing debts in full, and Husband shall be blameless as to the liability of the above credit cards. 7. It is averred that Wife has not adequately notified three credit card companies, Bank of America #549050099758441, Chase/Bank One #541762281658124, and HSBC Bank #5404240001472227, that the Plaintiff is not to be held liable for these debts and to remove his name from the credit card accounts in violation of Paragraph 4. 8. It is averred that the Plaintiff has made several expenditures in rectifying the situation and has suffered adverse reports on his credit scores because of Defendant's actions and continues to receive phone calls and letters regarding these debts (See Exhibit 3 attached hereto and incorporat®d herein as if fully set forth). 9. All attempts to gain consent to this petition have failed. 10. Judge Kevin A. Hess has been involved in this case since the Divorce Decree was issued on February 9, 2007. WHEREFORE, the Plaintiff requests that a hearing in this matter be scheduie s and that the Defendant be found in breech of the Marital Settlement Agreement as well as in contempt of the Court's Final Divorce Decree order and order that the Defendant provide evidence that the credit card companies have been notified of Defendant's sole liability for these debts within five days of the date of the Court's order. The Court order the Defendant to pay the reasonable attorney fees and costs incurred by the Plaintiff in seeking enforcement of the Courts order and the Mas;tp,l Settlement Agreement along with any other relief the Court deems appropriate. Respectfully submitted, Gal n R. Waltz, Esc Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 (717-245-9688 VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Le itner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Wilmer T.- Rit-nc-r a/k/a Lee Bitner Plaintiff NO. 06-4498 VERSUS Rosanna M Bi ner Defendant DECREE IN DIVORCE AND NOW, February 9 , 2007 , IT IS ORDERED AND DECREED THAT Wilmer L Bitner a/k/a Let- 'Rimer PLAINTIFF, AND Rosanna M. Bitner , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; Separation and Property Settlement Agreement is incorporated herein but not merged in the Divorce Decree. BY THE COURT: Kevin A. Hess ATTEST: J PROTHONOTARY ry 13, 007 PROPERTY SETTLEMENT AGREEMENT This Agreement, made and entered into this day of 199. -between Rosanna B'itner, of 55 Taylor Blvd., Harris Dauphin unty, Pennsylvania, herein referred to as I MW, and Lee Bitner of 1914 Sterrets Gap Avenue, Cumberland County, Pennsylvania, herein referred to as Husband 1, iEREAS, the parties hereto are now Wife and Husband, having been lawfully married to each other on May 92 1998 in Cumberland County, Pennsylvania; WHEREAS, the parties hereto are now living separate and apart since July 25, 2005 aril desire to enter into an Agreement -respecting their pmperty fights mgardless of the actual separation or other character thereof and their other rights, including the Wife's right to support and maintenance; WHEREAS, both and each of the parties hereto trove been add of their legal rights and the implies of this Agreement and the legal consequences that may and will amm from the executimi hereof, and each has had the opportunity to consult with his or her own competent legal counsel independent of each other; WHEREAS, each party warrants, as part of the consideration of this Agreement, that each has fury and completely disclosed all mformabon of a financial nature requested by the other, and that no information of such nature has been subject to distortion or in any manner being misrepresented; and WHEREAS, other than as set forth herein, Wife desires finally and forever to. relinquish all of her rights to be supported by Husband and all of her rights of dower, rights as heir or surviving spouse or otherwise, actual, currently existing, or inchoate, in and to the real and personal property of the Husband, now owned by -him or whi" the fixture may be owned by him, and all rights to counsel fees, or expenses and, other than as set forth herein, Husband likewise wishes to relinquish all his rights of curtsey. rights as heir or surviving spouse or otherwise, actual and currently existing or inchoate in and to the real and personal estate of the Wife, currently owned by her or which she may own in the future; NOW THEREFORE, the parties hereto intending to be legally bound hereby do hereby mutually agree as follows: 1. Separation. Husband and Wife do hereby mutually agree and consent to live separate and apart and do further agree that it shall be lawful for the Husband and Wife at all times hereafter to live separate and apart from each other, and to reside, from time to time, at such place or places as they respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each other. 2. No Molestation, Harassment or Interference. Neither party shall molest, harass or interfere with the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any means whatsoever. 3. Mutual Power and Estate Waiver. Except as otherwise expressly set forth herein, in which event such express provision shall take precedence over this paragraph, the parties hereto intend that from and after the date of this Agreement, neither shall have any spouse's rights in property or estate of the other, and to that end both parties waive, relinquish and forbear the rights of dower of curtsey, rights to inherit, rights to claim or take the Husband or Wife's or family exemption or allowance, to be vested with letters of administration or letters testamentary, or to take against any will of the other, and each agrees with the other if either should die intestate, his or her share shall descend to vest in his or her heirs at law, personal representatives, and next of kin, excluding the other as though he or she had died a widow or widower. And each further agrees that should the other die testate, his or her property shall descend to and vest in those persons set forth in the other's Last Will and Testament as though the spouse so designated as beneficiary had predeceased the testator. The parties further agree that they may and can hereafter, as though married, without any joinder by him or her, sell, convey, transfer or encumber any and all real estate and personal property which either of them now or hereafter own or possess and further agree that the recording of this Agreement shall be conclusive evidence to all of his or her right to do 2 so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given be necessary, the right and the power to appoint one or more times any person or persons whom the Husband or Wife shall designate to be the alt rney4n4act for the other, in their name. and in their stead, to execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or otherwise, to enable either party hereto to alienate his or her reel personal property, but without any power to impose personal rmbility for breach of warranty or otherwise. Each of the- parties hereto further waives any right.of election contained in Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an equitable distribution or married property ordered by the Court pubsequent to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that neither shalt hereafter be under any legal obligations to support the other, pay any mpenses for mahb_a e, funeral, burial, or otherwise for the other, and to that end each of the parties hereto does hereby waive any right to receive support, alimony, 'al mony pendente lite, counsel fees, expenses, or any type of financial assistance whatsoever from the other, except as otherwise expressly provided for herein. 4. Debt -W fe applied for and received the following credit cards without Husbands k nowkWge, authorization and agreement Furthermore, to maintain Husband's ignorance about the :relit cards provided to VVife, Wife secured a post office address. for credit caul statements which served to further deceive Husband as to the credit cards existence. : a. Capital One: 5178051815184229 b. Aspire Visa: 4331970850056173 c. Bank of America: 5447195200024105 d. Direct Merchants Bank: 5458000552891950 e. Chase Bank: 5417162281658124 / t Household Bank: 5404240001472227 g. Capital One: 5291151634658759 The paths agree that Wife shalt be responsible for the above existing debts in full, and Husband shalt be blameless as to the fiabiTity of the above credit cards. . 3 5. Future Debts. The parties further agree that neither will incur any more future debts for which the other may be held liable, and if either party incurs a debt for which the other will be liable, that party incurring such debt will hold the other harmless from any and all liability thereof. Personal Property. All Personal Property has been distributed as to the parties' satisfaction. 71 Divorce. The parties acknowledge that an action for divorce between them has been filed by Wife and is presently pending a divorce between them in the Court of Common Pleas of Cumberland County to the caption Wilmer L. Bitner, a/k/a Lee Bitner v. Rosanna M. Bitner, 2006-4498 Civil Term. The parties acknowledge their intention and agreement to proceed in said action to obtain a final decree in divorce by mutual consent on the grounds that their marriage is irretrievably broken, and to settle amicably and fully hereby all claims raised by either party in the divorce action. The parties acknowledged they have executed simultaneously herewith the 81 91 14 11 necessary Affidavits of Consent for the entry of a final divorce decree in that action. Breach. In the event that either party breaches any provision of this Property Settlement Agreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. Enforcement. The parties agree that this marital settlement agreement or any part or parts hereof may be enforced in any Court of competent jurisdiction. Applicable Law and Execution. The parties hereto agree that this Marital Settlement Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. This document shall be executed as original and multiple copies. The Entire Agreement. The parties acknowledge and agree that this Marital Settlement Agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are not other 4 representatives, wanwties, promises, covenants or understandings betNeen the parties other than those expressly set forth herein- Addrtional insbvmen s_ Each of the parties shall on demand or within a reasonable period thereafter, execute and delver any and all other doh and do or cause to be done any other act or things that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. 9 either party fails on demand to comply with this provision, that party shall pay to the -other all atlomey`s fees, costs, and other expenses reasonably incurred as a result of such failure. IN WIT NESS WHEREOF, the parties have set their hands and seals this day and year first written above. Wr-TNEsses t W °L Bitner aMa Lee fBdner /0000, J r ?? R94anna M_ Bidner w 5 P ,O. B(x oc-ol?. Chester, PA-19022 08/19/2008 TransUnion. Find an inaccuracy on your report? Submit your dispute online at: http://transunion.com/disputeonline PO L51500200292-100 268 5 WILMER LEE BITNER 1914 STERRETTS GAP AV CARLISLE, PA 17013 Enclosed is the TransUnion Personal Credit Report that you requested. As a trusted leader in the consumer credit information industry, TransUnion takes the accuracy of your credit information very seriously. We are committed to providing the complete and reliable credit information that you need to participate in everyday transactions and purchases. If you believe an item of information to be incomplete or inaccurate, please alert us immediately. We will investigate the data and notify you of the results of our investigation. To make it easier to request an investigation, you can now submit your request online, 24 hours a day, 7 days a week. You must have an active email address to use the online service. Please note that your email address will only be used for communicating with you regarding your request and the results of our investigation. Your email address will not be shared with any non-TransUnion entities. To submit an online request for investigation: Step 1. Go to the TransUnion online investigation service at http://transunion.com/disputeonline Step 2. Follow the instructions provided by the web site. Once submitted, you will receive online confirmation of your request. You will also be notified by email when we complete our investigation and your results will be available online. You can check the status of your investigation online by logging into your account. Thank you for helping ensure the accuracy of your credit information. TransUnion Consumer Relations P OL51S-002 00292-1002685 0111( TransUnion Personal Credit Score O WILMER LEE BITNER YOUR CREDIT SCORE Your Score & Grade .??. Score Not Purchased (See Below) Grade Created on 08/19/2008 C Based on your TransUnion credit report, this is a depiction of your creditworthiness. Score & Grade Range - 990 -900 Unavailable 806 (See Below) 700 1-600 W--501 I he numerical score ranges from 990 to 501 equaling grade ranges from A to F. Where You Rank 100'f, Unavailable 50% {See Belativj -0% Your credit ranks higher than % of the nation's population. About your TransUnion Personal Credit Score Your TransUnion Personal Credit Score is displayed above, and was calculated with the VantageScore credit scoring formula. Your credit score is a snapshot of the contents of your credit report at the time the score was calculated. Using objective, impartial formulas to translate the contents of your credit report into a 3-digit score enables lenders to evaluate your application for credit in a fast, fair and more objective manner. Remember, we constantly update the information contained in your credit report, so your TransUnion Personal Credit Score only represents the score a lender would receive if they requested it today. Summary You did not order a TransUnion credit score. You can purchase your credit score for $7-95 by calling 1-866-SCORE-TU or 1-866-726-7388. Answers About Credit Scores • How are credit scores used? A credit score is just one of several factors a company usually uses when deciding to extend credit, give insurance coverage or provide financial services to you_ A variety of otherfactors will be considered, such as length of employment, income or previous experience with you. Depending on what you are applying for, different companies weigh each of these factors differently. By using a credit score, they can evaluate your application quickly, fairly and consistently. • Now can 1 improve my credit score? A credit score is a snapshot of the contents of your credit report at the time it was calculated. Long-term, responsible credit behavior is the most effective way to improve future scores. Pay bills on time, lower balances and use credit wisely to improve your score over time. You should also review your credit report to ensure it is accurate. • How do inquiries affect my credit score? When your credit is checked by a business for the purpose of an application a 'hard inquiry' appears on your credit report. These inquiries can affect your credit score; and typically they have only a small impact. Delinquencies, balances owed, and the length of time you have used credit are all more important. Inquiries have a greater impact if you have a limited credit history. Additional Information The TransUnion Personal Credit Score is provided to help you better understand how lenders view your credit report. It is not an endorsement or a determination of your qualification for a loan. The VantageScore credit scoring model was used for this Score Analysis and is not necessarily the same scoring model that may be used by a lender. The resulting credit score may not be identical in every respect to any consumer credit score produced by any other company. Any credit information that has not yet been reported to TransUnion will not be reflected in your consumer disclosure or score. Also, some items disputed directly with creditors are not incorporated in the assessment of your credit score. Protect Yourself From i#y Theft Each year, 9 million people become victims of identity theft: Protect yourself. It's easy. We'll email you within 24 hours of any critical changes to your You'll swiftly find out about; • fraudulent activity • new inquiries • new accounts • late payments credit report. • and mom * Source: The FTC's national education campaign -AvolD Theft. Deter, Detect, Defend. File Number: 194224962 E?1 Page: 1 of 6 Datelssued: 08/19/2008 TransUnion. Name: WILMER LEE BITNER OtherNames: BITNER,W,L BITNER,LEE You have been on our files since 0111978 CURRENT ADDRESS Address: 1914 STERRETTS GAP AV CARLISLE, PA 17013 Date Reported: 11/2006 EMPLOYMENT DATA REPORTED EmployerName: RETIRED NAVY BASE Date Verified: 07/2008 EmployerName: US NAVY Date Reported- 01/2006 EmployerName: NAVAL INVENTORY Date Reported: 10/1999 EmployerName: NAVY SPCC Date Reported: 02/1992 SSN: XXX-)(X -9859 Date of Birth: 02/1949 Telephone: 728-0726 Your SSN is partially masked for your protection. PREVIOUS ADDRESS Address: 801 PEAR ST LEMOYNE, PA 17043 Date Reported: 1012006 Position: Hired: Position: Hired: Position: Hired: Position: Hired: Special Notes: Your Social Security number has been masked for your protection . You may request disclosure of the.full numberby writing to as at the address' found-Althe end of this repast- Aiso, if any item on your credit report begins wFth: *A" V, it includes medicatinfotMation and the data folfowing `MFD1' is not displayed to anyone but you except where permitted bylaw, The key to the right helps explain the payment history information N/A 1 "-J OK contained ire some of the accounts below. Not all accounts will contain paymetil history information, but some creditors report how you make Not 30 days 69 days 90 days 124 daiys paymeri% each month in relation to your agreementwith them. p Ual?oMn We late Late late llte following accounts rontaiginjorn)4 ion which some creditors may con sides to be adverse. Adverse account inlormation may genetalty be reported far 7 years from the date of The first detinquency,depending on your state of residence. the adverse information in these accounts has been printed in )brdcketscrris shaded for your convenience, to help you understand your report. They are not bracketed or shaded this way for creditors- (Note: The account# may be scrambled by the creditor for your pmtecOon). UNK OF AMERICA #5490500997584441 4060OGLETOWN STANTON RD Balance: $4,879 DE5-019-03-07 Date Updated: 05/2008 NEWARK, DE 19713 High Balance: $6,351 (800) 421-2110 Loan Type: CREDIT CARD Remarks:>PROFITAND LOSS WRITEOFR Estimated date that this item will be removed: 02/2013 Pay Status: >CHARGED OFFAS BAD DEBT< AccountType: REVOLVING ACCOUNT Responsibility: INDIVIDUAL ACCOUNT Date Open: 09/1997 Date Closed: 04/2008 To dispute online go to: http://transun'on.com/disputeontine P 01-51S-002 00292-1002687 03/1 -? Consumer Credit Report for WILMER LEE BITNER File Number: 194;'. ,46 Page- of Date Issued: OFs 9; ZDr,tk CHASE/BANK ONE CARD SERV #5417162281658124 800 BROOKSEDGE BEV Balance: $3,572 Pay Status: >CHARGED OFF AS BAD DEB I < Z WESTERVILLE, OH 43081 Date Updated: 08/2008 AccountType: REVOLVING ACCOUNT (800) 945-2000 High Balance: $3,572 Responsibility: INDIVIDUAL. ACCOUN' C Credit Limit: $3,000 Date Open: 12;1998 Loan Type: CREDIT CARD Past Due: >$31572< Date Closed: 0112002 Remarks: DISPUTE RESLVD-CUST DISAGREES Estimated date that this item will be removed: 12/2008 HSBC BANK #5404240001472227 PO BOX 5253 Balance: $0 Pay Status: >PAYMENTAFTER CHARGE CAROL STREAM, IL 60197 Date Verified: 0712007 OFF/COLLECTION< (800) 477-6000 High Balance: $5,279 AccountType: REVOLVING ACCOUNT Credit Limit: $0 Responsibilltr. INDIVIDUAL ACCOUNT Date Open: 11/1997 Loan Type: CREDIT CARD Date Closed: 03/2002 Remarks: DISPUTE RESLVD-CUST DISAGREES Date Paid: 0712005 n Estimated date that this item will be removed: 02/2009 r n The foltowft aecou"M are re{'F Lt tlwl h no adverse. information. (Now: The account # may be scrambled by the cfeditorfc yor- )- ASSOCIATES RNCL SERVICE #13759950409619 2480 E MARKET ST Balance: $0 Pay Status: PAID OR PAYING AS AGREED YORK, PA 17402-2409 Date Updated: 12/2000 AccountType: INSTALLMENT ACCOUNT (717) 741-6875 High Balance: $3,787 Responsibility: INDIVIDUAL ACCOUNT Terms: 36 MONTHLY $105 Date Opened: 12/1997 Loan Type: UNSECURED Date Closed: 12/2000 Remarks. CLOSED _ Late X X OK O K OK OK OK OK CITIRNANCIAL #13738180409791 5280 CORPORATE DR Balance: Pay Status: PAID OR PAYING AS AGREED FREDERICK, MD 21703 Date Updated: 09/1999 AccountType: INSTALLMENTACCOUNT Phone number not available High Balance: $3,787 .INDIVIDUAL ACCOUNT Terms: 36 MONTHLY $105 DataOpeaed 12/1997 Loan Type: NOTE LOAN GEMB/JCP #927096958 PO BOX 981402 Balance: $0 Paystalrrs: PAID OR PAYING AS AGREED EL PASO, TX 79998 Date Updated: 08/2008 AccountType: REVOLVING ACCOUNT (800) 542-0800 High Balance: $103 Responsibitity:INDIVIDUAL ACCOUNT Credit Limit: $200 Date Opened: 11/1997 Loan Type: CHARGE ACCOUNT Date Paid: 0312001 Late f OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK OK tiK 0K OK OK OK rOK OK ?OKK00111( OK t? OK -OK OK OK OKIO t?1( OK OK OK OK 0K OK OK GEMS/MONT WARDS #04165826213 PO BOX 981400 Balance: Pay Status: PAID OR PAYING AS AGREED EL PASO, TX 79998 Date Updated: 11/1999 Account Type: REVOLVING ACCOUNT (800) 950-0345 High Balance: $1,351 Responsibility: INDIVIDUAL ACCOUNT Credit Limit: $1,600 Date Opened: 02/1997 To dispute online go to: http://transunit?n.com/dispul•<eonline CERTIFICATE OF SERVICE I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of the Petition for Contempt , by first class, postage pre-paid and depositing same in the United States Mail, certified, return receipt requested, postage pre-paid on e, 2008, from Carlisle, Pennsylvania, addressed the day of as follows: Rosanna M. Bitner 52 Taylor Blvd. Harrisburg, PA 17103 TURO LAW OFFICES Ga en R. Waltz, Esquir 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 'u `n Wilmer L. Bitner aka Lee Bitner Plaintiff/Petitioner V. Rosanna M. Bitner Defendant/Respondent IN THE COURT OF COMMON PLEAS OF' CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4498 CIVIL TERM CIVIL ACTION - i_AW' RULE TO SHOW CAUSE AND NOW, this _ 6L day of -Siv -, 2008, upon receipt of th F"Ietition for Contempt, a Rule to Show Cause is issued upon Defendant to shoy,A- Gaul e. if any he has, why the relief requested therein should not be granted. This Rule is returnable 30 days from service BY THE COURT. I WWAIASNN3d 00 :11 WV 91 83S 800Z K&I I, c)c)Hi 3Hi d0 3 1-14 Wilmer L. Bitner aka Lee Bitner Plaintiff/Petitioner v Rosanna M. Bitner Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO 06-4498 CIVIL TERM CIVIL ACTION - LAW gdbbu PETITION FOR CONTEMPT RULE TO SHOW CAUSE AND NOW, comes Defendant/Respondent Rosanna M. Bitner and requests the honorable court to not find the defendant in contempt of this court's February 9, 2007 Decree in Divorce that incorporated the Property Settlement Agreement and offers the following in response to the Petition for Contempt: The Defendant/Respondent, Rosanna M. Bitner has adequately notified the three credit card companies, Bank of America, Account #549050099758442, Certified Letter No. 70080150000059921986, Chase/Bank One Account #541762281658124, Certified Letter No. 70080150000059921993, and HSBC Bank Account #5404240001472227, Certified Letter No. 70080150000059921979 that the Plaintiff is not to be held liable for these debts and to remove his name from the credit card accounts (Exhibits 1, 2 and 3). The Defendant is awaiting response from these three companies. The following is offered in response to the Rule to Show Cause: 1. The Defendant/Respondent has been and is in ill health, and underwent a heart catherization with stent implant on July 17, 2008. Continues to be on four (4) medications and has follow-up visits with cardiologist. The Defendant has incurred numerous out-of-pocket medical expenses ($5,000.00) not covered by medical insurance she had at the time. Defendant currently has no health insurance coverage for ongoing medical expenses. 2. The Defendant lost her job on August 10, 2008 and has been unemployed. 3. The Defendant does not own any property except for a 1996 vehicle. All income received is used for medical expenditures and monthly obligations (rent, utilities, automatic payment arrangements with credit card companies, IRS garnishment), therefore, it is requested that the Court recognize the Defendant is not financially able, at this time, and would cause further hardship to assume further liability for Defendant's attorney fees and costs. October 15, 2008 Bank of America Customer Service P. O. Box 15480 Wilmington, DE 19850 Re: Account Number 5447 1952 0002 4105 MasterCard Credit Card To Whom It May Concern: I am writing to inform you that I, Rosanna Bitner, obtained the above credit card in the name of my ex-husband, Wilmer L. Bitner without his knowledge or consent. His name must be removed from this account as I acknowledge it to be my full and complete responsibility for this account and that Mr. Bitner should not be held liable for this debt. I have been making monthly payments of $200.00 on this account to Client Serices, Inc. St. Charles, MO 63301 and will continue to do so. I have requested them to remove my ex-husband's name but have been informed that they cannot honor this request. Please contact me by telephone at 717-265-6614 or by mail at 52 Taylor Boulevard, Harrisburg, PA 17103 to discuss and rectify this matter. October 15, 2008 Chase Bank Cardn-ember Services P.O. Box 15153 Wilmington, DE 19886 Re: Account Number 5417 1622 8165 8124 Visa, Credit Card To Whom It May Concern: I am writing to inform you that I, Rosanna Bitner, obtained the above credit card in the name of my ex-husband, Wilmer L. Bitner without his knowledge or consent. His name must be removed from this account as I acknowledge it to be my full and complete responsibility for this account and that Mr. Bitner should not be held liable for this debt. I further agree to pay this debt and would be able to do so on a monthly payment basis. I request that you contact me by telephone at 717-265-6614 or by mail at 52 Taylor Boulevard, Harrisburg, PA 17103 to discuss and rectify this matter. M. Bitner d? LL4,a, ;2- r-31 (5 1 4 Wilmer L. Bitner aka Lee Bitner : IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA N. NO. 06-4498 CIVIL TERM Rosanna M. Bitner : CIVIL ACTION - LAW Defendant/Respondent _ ORDER AND NOW, this L 4i of G!, 2009 a hearing on the Plaintiff/Petitioner's Petition for Cont pt is scheduled for the /l*q day of 2009, in Courtroom No. 1,4 at /! 3 d arripm. BY THE COURT, J. cc: Galen R. Waltz, Esquire Rosanna M. Bitner c ks rna.14ac -31 ? a u cr N U WILMER L. BITNER aka LEE BITNER, Plaintiff/Petitioner V. ROSANNA M. BITNER, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-4498 CIVIL TERM IN RE: PETITION FOR CONTEMPT ORDER OF COURT AND NOW, this 11th day of March, 2009, hearing herein is continued until Wednesday, June 17, 2009, at 9:15 a.m., in accordance with the terms and conditions as announced in open court and in the presence of the parties this date. The court directs that a transcript of these proceedings be made and filed of record. By the Court, ''Galen R. Waltz, Esquire For the Plaintiff ? Kosanna M. Bitner, Pro se :bg Cow C &S t-n= '3 !3 0c? l1 Kevin Al. Hess, J. ` C7 a °a G .ca ...? .,;_.°, c?% -,Vs ? -? ?? ?" .P --G, C? WILMER L. BITNER aka LEE BITNER, Plaintiff/Petitioner: V. ROSANNA M. BITNER, Defendant/Respondent: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-4498 CIVIL TERM IN RE: PETITION FOR CONTEMPT ORDER OF COURT AND NOW, this 17th day of June, 2009, on agreement of the parties, hearing herein is continued until Friday, September 11th, 2009, at 9:15 a.m. By the Court, Hess, J. If ? Galen R. Waltz, Esquire For the Plaintiff/Petitioner Rosanna M. Bitner Pro se :lfh eo?I e.?-T maj (ccL - , /'Y) FILET L CF r- 'CNq 20D9 JUN 18 AV, 8.4 7 WILMER L. BITNER a/k/a IN THE COURT OF COMMON PLEAS OF LEE BITNER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW VS. NO. 06-4498 CIVIL ROSANNA M. BITNER, Defendant IN RE: PETITION FOR CONTEMPT ORDER AND NOW, this Ir day of September, 2009, at the request of the parties, hearing in the above-captioned matter set for September 11, 2009, is continued generally. BY THE COURT, A. Hess, J. Galen R. Waltz, Esquire For the Plaintiff ? Rosanna M. Bitner, Pro Se 52 Taylor Blvd. Harrisburg, PA 17103 rlm 00F Ces /n?l L LL 9/1 1 /,51 OF THE 2009 SEP 1 i AM 9: 4 3 CU??- ?i??1TY PENNSYC AINVA