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06-5297
JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 24 N. 32ND Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorneys for Plaintiff MARIE RUHLAND, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. O(a - s? 4 C Coe GLEN RUHLAND, 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 may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff MARIE RUHLAND, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. GLEN RUHLAND, Defendant NO. CIVIL ACTION -LAW IN DIVORCE AVISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio o anulamiento puede ser emitado en su contra por la Corte. Una decision puede tambien ser emitida en su contra por caulquier otra queja o compensaction reclamados por el demandante. Usted puede perder dinero, o sus propiedades o otros derechos importantes para usted. Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDO PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 MARIE RUHLAND, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01. -- .5247 el C ;t 1.? GLEN RUHLAND, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. Plaintiff is Marie Ruhland, an adult individual who currently resides at 2725 Lisburn Road, Camp Hill, PA, Cumberland County, Pennsylvania, 17011. 2. Defendant is Glen Ruhland, an adult individual who currently resides at 41 Lois Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 17, 1958 in Paradise Township, Adams County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that are no minor children of this marriage. 8. The Plaintiff avers that the grounds on which the action is based are as follows: (a) The marriage is irretrievably broken 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301 (c) of the Divorce Code. COUNT II EOUITABLE DISTRIBUTION 12. Paragraphs one (1) through eleven (11) of this Complaint are incorporated herein by reference. 13. Plaintiff and Defendant have acquired property, both real and personal, during their marnage. 14. The parties have acquired marital debt during their marriage. 15. Plaintiff and Defendant may be unable to resolve amicably the property issues in this matter. WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all marital property and debt. COUNT III ALIMONY, ALIMONY PENDENTE LITE, COUNCEL FEES, COSTS, AND EXPENSES 16. By reason of this action, Plaintiff has and/or may incurr considerable expense in the preparation of her case and the employment of counsel and the payment of costs. 17. The Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation. 18. Plaintiff has no income nor is she able to engage in employment to provide for her reasonable needs and to pay her attorneys' fees and the cost of this litigation and she is unable to appropriately maintain herself during the pendency of this action. 19. Defendant has adequate earnings to provide for the Plaintiffs support and to pay her counsel fees, costs and expenses. 20. Plaintiff lacks sufficient property to provide for her reasonable needs. 21. Plaintiff is unable to support herself through appropriate employment. 22. Defendant has sufficient income and assets to provide continuing support for the Plaintiff. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order granting Plaintiff Alimony Pendente Lite, award Plaintiff interim counsel fees, costs and expenses, and award Plaintiff permanent Alimony. Date: .. 3 ?, 0(, Respectfully submitted, Attorney ID No.: 3& 24 N. 32nd Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff JOANNE HARRISON CLOUGH, PC VERIFICATION I, Marie Ruhland, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: Marie Ruhland r? Gli I?E 0 c i ac c ? c ? c? a 1 A -ft KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MARIE RUHLAND Plaintiff, NO. 06-5297 vs. CIVIL ACTION - LAW IN DIVORCE GLEN RUHLAND , Defendant. PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Lesley J. Beam, Esq, of Kope & Associates, LLC of 4660 Trindle Road, Suite 201, Camp Hill, Pennsylvania 17011, on behalf of the Defendant, Glen Ruhland, in connection with the above-captioned divorce action. Respectfully Submitted, Date: tD 14J& BY: Lesley . $eam, Esquire ID# 91J75 4660 Trindle Road Suite 201 Camp Hill, PA 17011 (717) 761-7573 KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 IbearnAkopelaw.com MARIE RUHLAND Plaintiff, vs. GLEN RUHLAND , Defendant. CERTIFICATE OF SERVICE I, Lesley J. Beam, Esquire do hereby certify that on this 3rd day of October, 2006, 1 served a true and correct copy of the foregoing Praecipe to Enter Appearance via regular U.S. First Class mail, postage prepaid, addressed as follows: Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5297 CIVIL ACTION - LAW IN DIVORCE Joanne Harrison Clough, Esquire 24 N. 32nd Street Camp Hill, PA 17011 KOPE & A§SOCIATES, LLC By: Ly L ey J. jeafn,Esq. I.D. 9117 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 ? :f ?? --? C_.. is U' ? ?.y ? y i'S f:.." J -;7f I,,,,,J ' "S (,.,? t '?... ?? .. -? { ?? .-? r--? -?»? ,',? MARIE RUHLAND, Plaintiff V. GLEN RUHLAND, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5297 Civil Term CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Lesley J. Beam, Esquire acknowledge that I am legal counsel for Defendant, Glen Ruhland.. I further acknowledge that I received a true and correct copy of a time stamped Complaint in Divorce filed on September 11, 2006 in the above captioned action by first class mail on the day of September, 2006 and I accept service of said Complaint on behalf of the defendant. Date: J. /Beam, Esquire Kope & Associates 4660 Trindle Road Suite 201 Camp Hill, PA 17011 Attorney for Defendant Glen Ruhland C3 s 7F JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 24 N. 32NDStreet Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorneys for Plaintiff MARIE L. RUHLAND, Plaintiff V. GLEN A. RUHLAND, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5297 Civil Term : CIVIL ACTION -LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff MARIE L. RUHLAND, Plaintiff V. GLEN A. RUHLAND, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06- 5297 Civil Term : CIVIL ACTION -LAW : IN DIVORCE AVISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio o anulamiento puede ser emitado en su contra por la Corte. Una decision puede tambien ser emitida en su contra por caulquier otra queja o compensaction reclamados por el demandante. Usted puede perder dinero, o sus propiedades o otros derechos importantes para usted. Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAM ENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDO PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 MARIE L.RUHLAND, Plaintiff V. GLEN A. RUHLAND, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5297 civil Term : CIVIL ACTION -LAW : IN DIVORCE AMENDED COMPLAINT IN DIVORCE UNDER SECTION 3301(a)(2) and 3301(a)(6) and 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Marie L.Ruhland, an adult individual who currently resides at 2725 Lisburn Road, Camp Hill, PA, Cumberland County, Pennsylvania, 17011. 2. Defendant is Glen A.Ruhland, an adult individual who currently resides at 41 Lois Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 17, 1958 in Paradise Township, Adams County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that are no minor children of this marriage. 8. The Plaintiff avers that the grounds on which the action is based are as follows: (a) The marriage is irretrievably broken (b) The Defendant has committed and continues to commit adultery. (c) The Defendant has offered indignities to the plaintiff, the injured and innocent spouse, so as to make Plaintiffs condition burdensome and life intolerable; 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301 (a)(2) or, 3301 (a)(6) or, 3301 (c) of the Divorce Code. COUNT II EQUITABLE DISTRIBUTION 12. Paragraphs one (1) through eleven (11) of this Complaint are incorporated herein by reference. 13. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. 14. The parties have acquired marital debt during their marriage. 15. Plaintiff and Defendant may be unable to resolve amicably the property issues in this matter. WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all marital property and debt. COUNT III ALIMONY, ALIMONY PENDENTE LITE, COUNCEL FEES COSTS, AND EXPENSES 16. By reason of this action, Plaintiff has and/or may incurr considerable expense in the preparation of her case and the employment of counsel and the payment of costs. 17. The Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation. 18. Plaintiff has no income nor is she able to engage in employment to provide for her reasonable needs and to pay her attorneys' fees and the cost of this litigation and she is unable to appropriately maintain herself during the pendency of this action. 19. Defendant has adequate earnings to provide for the Plaintiff s support and to pay her counsel fees, costs and expenses. 20. Plaintiff lacks sufficient property to provide for her reasonable needs. 21. Plaintiff is unable to support herself through appropriate employment. 22. Defendant has sufficient income and assets to provide continuing support for the Plaintiff. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order granting Plaintiff Alimony Pendente Lite, award Plaintiff interim counsel fees, costs and expenses, and award Plaintiff permanent Alimony. Respectfully submitted, JOANNE HARRISON CLOUGH, PC Date: Joanne Hazy n Clough, Esquire Attorney ID No.: 36461 24 N. 32nd Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff VERIFICATION I, Marie L. Ruhland, hereby verify and state that the facts set forth in the foregoing pleading 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. Section 4904 relating to unsworn verification to authorities. DATE: l D Marie L. Ruhland r-? r? r r CJ MARIE L.RUHLAND, Plaintiff V. GLEN A. RUHLAND, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5297 civil Term CIVIL ACTION -LAW IN DIVORCE MOTION FOR APPOINTMENT OF SPECIAL MASTER Plaintiff, Marie L. Ruhland, moves the Court to appoint a Special Master with respect to the following claims: ( x ) Divorce ( x ) Equitable Distribution of Property ( x ) Annulment ( x ) Alimony ( x ) Counsel Fees ( x ) Alimony Pendente Lite ( x ) Costs and Expenses (1) Discovery is complete as to the claims for which the appointment of a master is requested as follows: Plaintiff served Request for Production of Documents and Interrogatories. Served on February 12, 2007. Revised Interrogatories were served on March 7, 2007 and served a second revised set of Interrogatories was served on March 20, 2007. (2) The Defendant has appeared in the action by his attorney, Leslie J.Beam, Esquire. (3) The statutory grounds for divorce are irretrievable breakdown (3301 [c]) or indignities (3301 [a]). (4) The action is contested with respect to the following claims: Divorce, Equitable Distribution, Alimony, Alimony Pendente Lite, and Counsel Fees, Costs, and Expenses. (5) The action does not involve complex issues of law or fact. (6) The hearing is expected to take one (1) day. (7) Additional information, if any, relevant to the motion: None. Joanne H rrison ClougA Attorney I.D. No. 36461 24 N. 32nd Street Camp Hill, PA 17011 (717) 737-5890 Attorney for ?? ?? DATED: t ? t ^ :751 - ? J `ice' MARIE L.RUHLAND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5297 GLEN A. RUHLAND, CIVIL ACTION -LAW Defendant IN DIVORCE PETITION FOR SPECIAL INJUNCTIVE RELIEF TO PREVENT DISSIPATION OF MARITAL ASSETS AND NOW, this flay of April, 2007, comes the Petitioner Plaintiff Marie L. Ruhland, by and through her attorney, Joanne Harrison Clough, Esquire and respectfully files this Petition for Special Injunctive Relief to Prevent Dissipation of Marital Estate and in support thereof avers as follows: 1. Plaintiff is Marie L.Ruhland, an adult individual who currently resides at 2725 Lisburn Road, Camp Hill, PA, Cumberland County, Pennsylvania, 17011. 2. Defendant is Glen A.Ruhland, an adult individual who currently resides at 41 Lois Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The Plaintiff and Defendant were married on August 17, 1958 in Paradise Township, Adams County, Pennsylvania. 4. During the course of this 48 year marriage, the parties acquired a substantial toy collection consisting of tens of thousands of collectible antique and other toy cars, tractors and numerous other valuable collectibles with a value believed to be in excess of One Hundred Thousand Dollars ($100,000.00). 5. The toy collection completely fills the parties' basement from floor to ceiling and portions are also stored in a garage and other outbuildings at the marital residence located at 2725 Lisburn Road, Camp Hill, PA. 6. Although Defendant lives with his paramour and sleeps at her home each evening, he has been returning to the marital residence daily and has been removing numerous items from the parties' valuable toy collection and has been selling them without the permission of Petitioner Plaintiff. 7. Defendant husband and his paramour were recently seen at a toy sale where they had set up a booth and Defendant was selling some of the parties' toy collection without Petitioner Plaintiff wife's permission. 8. Petitioner Plaintiff served Interrogatories and Request for Production of Documents and two sets of revised interrogatories on Defendant husband during the past three months requesting in part, a listing of the entire toy collection inventory and all related records, which to date remain unanswered by the Defendant. 9. Since November of 2006 Defendant, by and through his legal counsel have contested Plaintiff's estimated value of the toy collection and have indicated they were sending an inventory and/or valuation of said collection but have failed to send any such information. 10. During the entire time that Plaintiff has requested this information from Defendant, he has been systematically returning to the house daily and removing items from the toy collection and selling them or otherwise removing them from the marital residence without accounting for them to Plaintiff and/or her legal counsel. 11. Plaintiff has an equitable distribution claim pending in this Divorce Action and Defendant is dissipating the marital assets without Plaintiff s permission and said dissipation may cause irreparable harm since said items are being sold at toy sales or by other means that may not have traceable records by which Plaintiff can determine the items sold by Defendant or the monies received for said sales. 12. Section 3505 (a) of the Pennsylvania Divorce Code when it appears to the court that a party is about to remove property from the jurisdiction of the court or dispose of property to defeat a claim for equitable distribution, an injunction may be issued to prevent the removal and disposition of the property. 13. Petitioner Plaintiff is of the belief and therefore avers that Defendant is regularly removing valuable items from the marital residence and selling them or otherwise transferring a and disposing of them in an attempt to dissipate the marital estate and prevent Petitioner Plaintiff from being able to determine the actual value of the marital estate. 14. Defendant Respondent does not concur in this Petition for Special Relief. 15. This action/matter has not been previously assigned to any Judge. WHEREFORE, Petitioner Plaintiff Marie Ruhland respectfully requests this Honorable Court to issue an injunction against Defendant Glenn Ruhland preventing him from removing, transferring selling or otherwise disposing of any of the toy collection or any other personal property without Petitioner or the Court's approval and direct Defendant to provide a complete inventory of all of the items he has removed from the marital residence and the current location of each item or the monies or other value received for each removed item that he sold or otherwise transferred for value. Respectfully submitted, Date: q ?' JOANNE HARRISO /LOUGH, PC Joanne Harrison Clou Attorney ID No.: 3 24 N. 32nd Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff Esquire VERIFICATION I, Marie L. Ruhland, hereby verify and state that the facts set forth in the foregoing pleading 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. Section 4904 relating to unsworn verification to authorities. DATE: Marie L.' Ruhland CERTIFICATE OF SERVICE I, Joanne Harrison Clough, Esquire, do hereby certify that on this date I served a copy of the foregoing document by United States First Class Mail, on April , 2007to the following individual set forth below: Leslie J. Beam, Esquire Kope & Associates, LLC 4660 Trindle Road Suite 201 Camp Hill, PA 17011 r Date: -D Joanne arrison Clough, E uire Attorney ID No. 36461 24 N. 32nd Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Defendant f S 11 +, • 1r ? t t :? f! 4 f CD tlA7 n ? i -? M M'? MARIE L.RUHLAND, Plaintiff V. GLEN A. RUHLAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5297 civil Term CIVIL ACTION -LAW IN DIVORCE ORDER APPOINTING SPECIAL MASTER AND NOW, this 36-a day of- 2007, G • Esquire, is appointed Special Master with respect to the following claims: Divorce, Equitable Distribution, Alimony, Alimony Pendente Lite, and Counsel Fees, Costs and Expenses. BY THE CQURT, 1 J. ;..1 I I-- p?]?J r, - e+? 31 l1 ; 3 OF THEE 71107 APR 30 A 11: 51 APRR32007 P'` Y MARIE L.RUHLAND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5297 GLEN A. RUHLAND, : CIVIL ACTION -LAW Defendant : IN DIVORCE RULE TO SHOW CAUSE AND NOW, this ?? `3ay of April, 2007, after review of the attached Petition for Special Injunctive Relief to Prevent Dissipation of Marital Assets, a Rule is issued, to show cause, if any, why Petitioner Plaintiff Marie Ruhland's petition should not be granted and why an Order should not be issued preventing Defendant, Glen Ruhland, from removing, transferring selling or otherwise disposing of any of the toy collection or any other personal property without Petitioner or the Court's approval and why Defendant should not be ordered to provide a complete inventory of all of the items he has removed from the marital residence since the divorce action was filed and the current location of each item or the monies or other value received for each removed item that he has sold or otherwise transferred for value. rnable within Lo days of date of service. Rule re t z?. i wl No property shall be sold, removed or transferred by Defendant until further Order of Court. BY THE C7/,? 1( /./ J. N KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 lbeam@kopelaw.com MARIE L. RUHLAND, Plaintiff, vs. GLEN A. RUHLAND, Defendant. Attorney for Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5297 : CIVIL ACTION - LAW : IN DIVORCE RESPONSE TO RULE TO SHOW CAUSE and ANSWER TO PLAINTIFF'S PETITION FOR SPECIAL INJUNCTIVE RELIEF AND NOW, this 15?h day of May, 2007, comes Respondent/Defendant Glen A. Ruhland, by and through his attorney, Lesley J. Beam, Esquire, and respectfully files this Response to Rule to Show Cause and Answer to Plaintiff's Petition for Special Injunctive Relief, and in support thereof avers the following: Answer 1. Admitted. 2. Denied. It is specifically denied that Defendant resides at 41 Lois Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17055. To the contrary, Defendant resides at 2725 Lisburn Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Admitted. 4. Denied. During the course of the marriage, Defendant acquired a toy collection as his hobby, finding and purchasing numerous assorted toys, specifically Matchbox cars and farm toys, etc. The actual value of these toys is currently unknown to Defendant, as well as Plaintiff. Defendant has provided Plaintiff with all of the computer files that contain inventories of the toys purchased, with purchase prices, and estimated values. These estimated values constitute educated guesses by Defendant, who has no professional training in such, and cannot be held to be actual values of the toys. Furthermore, Defendant currently believes that the toy collection to be worth roughly $20,000 to $30,000, but does not know this to be accurate. 5. Admitted in part; denied in part. It is admitted that the toy collection is located in its entirety at the parties' home. It is denied that the collection completely fills the basement from floor to ceiling, as this is a gross overstatement and exaggeration. Defendant's toy collection does consist of numerous toys, the inventories of which have been provided to Plaintiff. 6. Denied. It is denied that Defendant lives anywhere but his residence at 2725 Lisburn Road in Camp Hill, Pennsylvania. It is further denied that Defendant has been returning to the marital residence daily, removing numerous items and selling them without Plaintiffs permission. Defendant has sold several toys on one occasion, in an effort to ascertain values of the toys, as a response to Plaintiffs repeated, non-stop inquiries into the value of the toy collection. By way of further answer, Defendant bought and sold these toys throughout the entirety of his marriage to Plaintiff, kept logs and records and the like, and Plaintiff has never had any involvement with any of these transactions. As such, Defendant was under no obligation to consult Plaintiff on the selling of a handful of toys. Further, Plaintiff has been regularly removing china and other 2 antiques from the marital residence, and has not discussed the matter of their removal, nor provided an inventory of such, to Defendant. It is believed that Plaintiff has been giving away marital property to the parties' children in an effort to keep such property from Defendant. 7. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief to the truth of this averment. It is unknown what an unidentified person did or did not see. 8. Admitted in part; denied in part. It is admitted that Plaintiff served Interrogatories over the past few months, however, these documents contained gross violations of the number of interrogatories permitted, and as such, Defendant exercised his right to ask Plaintiff to amend her interrogatories in compliance with local rule. It is further admitted that at the time of Plaintiffs Special Petition, Defendant had not answered the Interrogatories. In fact, Defendant's time limit had not yet been reach on responding to the Interrogatories at the time of the filing of Plaintiffs Special Petition. It is denied to the extent that Plaintiff alleges that Defendant as not been forthcoming with the information requested. To the contrary, Plaintiff requested years and years of documented and undocumented information, almost the entirety of which was information within her access and control. To date, Defendant has answered Plaintiffs last set of Interrogatories and Request for Production of Documents, and provided Plaintiff with a copy of all of his inventory records for the toy collection. By way of further answer, it should be noted that at all times, this inventory was contained in the computer located within the parties' home and within Plaintiffs control. 3 9. Admitted in part; denied in part. It is admitted that Defendant has contested Plaintiffs completely fabricated value of Defendant's toy collection; it is denied that no information concerning the toy collection has been sent. To the contrary, as stated above, a complete copy of all inventory records has been sent to Plaintiff, despite the fact that these records were readily available to Plaintiff as they were located within her own home. 10. Denied. It is denied that Defendant has engaged in "systematic" conduct. It is denied that Defendant has been removing property during the "entire time" that Plaintiff has requested information from Defendant. Rather, Defendant has removed and sold only a handful of toys from the home, for the purpose of ascertaining actual value of the toys for the purpose of determining a marital estate. Further, Plaintiff has a complete copy of all the inventory records for the toys - all of the information that Defendant has regarding the toy collection. 11. Admitted in part; denied in part. It is admitted that there is an equitable distribution claim pending in this divorce action wherein the marital assets will be divided. It is specifically denied that Defendant is dissipating the marital assets without Plaintiffs permission and that this dissipation will cause irreparable harm. To the contrary, the parties have a significant marital estate, constituting financial accounts and IRAs, a home with adjacent property, savings bonds, etc. Plaintiff has been provided with statements concerning all of the marital assets, as well as a complete copy of Defendant's inventory records of the toys. As such, the value of the marital estate will not be affected by Defendant selling toys now that Plaintiff has neither taken any part in acquiring nor shown 4 any interest in retaining. Further, Plaintiff continues to remove antiques, china, and the like from the home, without accounting for such to Defendant or Defendant's counsel. It is clear that the only irreparable harm to be effected here would be to Defendant, and Plaintiff most assuredly does not maintain an inventory of the family possessions which she is regularly removing from the marital home. 12. Admitted. 13. Denied. It is denied that Defendant is regularly removing items from the marital residence, it is denied that any items that have been removed are valuable, and it is denied that Defendant is selling, transferring and/or disposing them in an effort to dissipate the estate and prevent Plaintiff from determining an actual value. To the contrary, and as stated above, Defendant is not regularly removing items from the marital residence. It is further denied that any items that have been removed, specifically, the few toy which Defendant has removed, are valuable. To the contrary, these toys that have been sold are literally worth change to $5 dollars per toy, at most. Further, it is denied that Defendant is selling anything to prevent Plaintiff from determining an actual value. To the contrary, Defendant has provided Plaintiff with a complete copy if his inventory records for the collection. 14. Admitted. 15. Admitted. New Matter 16. Plaintiff stands in possession and/or control of not only the toys at question, but a complete copy of the inventory records for these toys. It is incumbent 5 upon Plaintiff to take the necessary steps to either agree to a value with Defendant for the purposes of equitable distribution, and/or secure professional valuation of such. Plaintiff has done neither. 17. Plaintiff has not alleged the disbursement of any items of value except for a portion of the toys in Defendant's toy collection. Plaintiffs statement of value for these items is a completely fabricated value. 18. Plaintiff has regularly requested that Defendant compile all of the information regarding the estate for Plaintiff's use, despite the fact that this documentation is in Plaintiff's residence for her own review. 19. As Plaintiff has possession and control of all of the toys currently owned in the toy collection, and a statement of inventory for the toys, Plaintiff has no need for a specific inventory of any toys removed and/or sold by Defendant. 20. Plaintiff currently holds copies of all documentation of the marital assets of the parties; as such Plaintiff is fully able to determine a value of the marital estate. The parties hold substantial value in marital assets in the home and attached property, IRA accounts, other financial accounts, savings bonds, etc. Plaintiff's ability to determine the value of a marital estate, and recover her portion thereof, is not affected by Defendant selling a few toys, worth a few dollars apiece. 21. It should be noted that the parties' current income is primarily composed of the retirement annuity from Defendant's service with the United States Postal Service, and would be considered marital property under Pennsylvania case law. It must be noted that this income is required to support both Plaintiff and Defendant, and, 6 as such, any Order by Court preventing the dissipation and/or use of marital property by the Defendant and/or by Plaintiff should not include this retirement annuity. 22. Further, as previously discussed, it has come to Defendant's attention that various items of antiques and china have been disappearing from the marital residence when he is not home. It is believed, and therefore averred, that Plaintiff is removing these items and either selling them or giving them to the parties' children for the purpose of preventing Defendant's ownership of such, and precluding the consideration of the objects in the estimation of the marital estate. 23. Plaintiff has not provided an inventory of the objects removed, nor of their current value to either Defendant, or Defendant's counsel. Unlike Plaintiff, who currently holds a complete copy of Defendant's inventory records of the toy collection, Defendant does not hold any information regarding these valuable marital possessions. It is requested that in the event that an Order be entered by the Honorable Court that Plaintiff be required to provide an inventory of these objects that have been removed and of their current value to Defendant. 24. Pursuant to § 3505(a) of the Divorce Code of Pennsylvania, an injunction may be issued where it appears the property is about to be disposed of, alienated or encumbered in order to defeat equitable distribution. 25. In the within divorce action, Defendant has provided documentation allowing Plaintiff to ascertain the value of the marital estate. Further, the parties have numerous assets, including financial accounts and real property, available for 7 distribution which have not been, nor will be, disposed of prior to equitable distribution of the assets. 26. As such, the requested injunction is not required as the alleged conduct of Defendant cannot result in a thwarting of equitable distribution. WHEREFORE, Respondent Defendant Glen Ruhland respectfully requests that this Honorable Court deny Petitioner's Petition for an injunction against Defendant Glen Ruhland. It is further requested that this Honorable Court deny Petitioner's request for a complete inventory of items removed and their current location as unwarranted, extraneous and frivolous. Respectfully Submitted, BY: Date: Esquire Lesley ?' eZad I D# 91 4660 Tnndle Suite 201 Camp Hill, PA 17011 (717) 761-7573 8 VERIFICATION I, Glen A Ruhland, the Respondent Defendant in this matter, have read the foregoing Response to Rule to Show Cause and Answer to Plaintiffs Petition for Special Injunctive Relief. I verify that my averments in this Complaint are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities. Dated: / Glen A. Ruhland KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 lbeam@kopelaw.com Attorney for Plaintiff MARIE RUHLAND : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06-5297 GLEN RUHLAND CIVIL ACTION - LAW Defendant. IN DIVORCE CERTIFICATE OF SERVICE I, Lesley J. Beam, Esquire do hereby certify that on this 16th day of May, 2007, 1 served a true and correct copy of the foregoing Response to Rule to Show Cause and Answer to Plaintiffs Petition for Special Relief via regular U.S. First Class mail, postage prepaid, addressed as follows: Joanne Harrison Clough, Esquire 24 N. 32nd Street Camp Hill, PA 17011 KOPE & ASSOCIATES, LLC By: t,etl6y J. 13 T , Esq. D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 '--9 V-7 . MARIE L. RUHLAND, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW GLEN A. RUHLAND, Defendant NO. 06-5297 CIVIL TERM ORDER OF COURT AND NOW, this 21" day of May, 2007, upon consideration of Plaintiff s Petition for Special Injunctive Relief To Prevent Dissipation of Marital Assets, and of Defendant's Response to Rule To Show Cause and Answer to Plaintiff's Petition for Special Injunctive Relief, a hearing is scheduled for Wednesday, August 8, 2007, at 1:30 p. m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, ,/?oanne Harrison Clough, Esq. 24 N. 32nd Street Camp Hill, PA 17011 Attorney for Plaintiff esley J. Beam Esq , . 4660 Trindle Road Suite 201 Camp Hill, PA 17011 ,3 Attorney for Defendant :rc i t { '?, ? ,d"??7 e ?: t r . 1? ,t;;? ll.J`<`" .? ; ?;??1. rill ?-? j'-' MARIE L. RUHLAND, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW GLEN A. RUHLAND, Defendant 06-5297 CIVIL TERM IN RE: AGREEMENT OF THE PARTIES ORDER OF COURT AND NOW, this 8th day of August, 2007, upon consideration of Plaintiff's Petition for Special Injunctive Relief To Prevent Dissipation of Marital Assets, and of Defendant's Response to Rule To Show Cause and Answer to Plaintiff's Petition for Special Injunctive Relief, and pursuant to an agreement reached in open court on today's date by counsel in the presence of the parties, it is ordered and directed as follows: 1. An order is now entered preventing either party from removing, transferring, selling or otherwise disposing of any marital asset, regardless of whether jointly or individually titled, without prior agreement of the parties or court approval. 2. Notwithstanding the foregoing, husband shall retain the proceeds from the DWS Skudder account in the amount of $47,432.45 he liquidated on May 8th, 2007, as a partial equitable distribution award in this divorce action. 3. Wife shall also receive her DWS Skudder account with a June 30th, 2007, account value of $27,976.35 and two $10,000 series EE savings bonds numbered X2171090EE and X2171091EE, each with a value of $11,448, which are currently in husband's possession as a partial equitable distribution order to wife. Husband shall immediately transfer the two $10,000 savings C r;j C? It, Z bonds to husband's counsel, and the respective attorney shall arrange the transfer of the bonds to wife. 4. In consideration of the parties reaching this agreement today, wife agrees to not file the Petition for Contempt that she prepared, and will not seek a finding of contempt against husband for any other pre-dissipation of assets that has occurred from the date of filing of wife's Petition for Special Relief. oanne Harrison Clough, Esquire 24 N. 32nd Street Camp Hill, PA 17011 For Plaintiff / "sley J. Beam, Esquire ?? 4660 Trindle Road Suite 201 Camp Hill, PA 17011 For Defendant :mae O By the Court, Joanne Harrison Clough, Esquire Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff MARIE L.RUHLAND, Plaintiff V. GLEN A. RUHLAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5297 Civil Term CIVIL ACTION - LAW IN DIVORCE PRELIMINARY PRE-TRIAL STATEMENT OF PLAINTIFF MARIE L. RUHLAND I. BACKGROUND INFORMATION: PLAINTIFF: 1. Name: Marie L. Ruhland 2. Address: 2725 Lisburn Road Camp Hill, PA 17011 3. Age: 69 4. Date of Bi rth: April 1, 1938 5. Educational Background: High School Graduate 1957 6. Health: Fair (borderline) a. Diabetes b. Irritable Bowel Syndrome c. Pancreatitis d. Acid Reflux e. Heart Problems f. Arthritis g. Cirrohosis h. Miscellaneous additional health issues 7. Occupation: Homemaker/retired less than 40 quarters contributing to Social Security; 8. Employer: None. Receives $ 41.00 per month from said security DEFENDANT: 1. Name: Glen A. Ruhland 2. Address: 2725 Lisburn Road Camp Hill, PA 17011 3. Age: 68 4. Date of Birth: October 9, 1939 5. Educational Background: High School Graduate, Some college education 6. Health: Good 7. Occupation: Supervisor U.S. Postal Service Retired, Auto Sun Roof and STATOD Enterprises, Inc Harrisburg Auto Auction 8. Employer: Auto Sun Roof and Harrisburg Auto Auction CHILDREN OF THIS MARRIAGE: 1. Glenda Sites Date of Birth: November 9, 1959 2. Dale Ruhland Date of Birth: May 29, 1972 MARRIAGE INFORMATION: 1. Date of Marriage: August 17, 1958 2. Place of Marriage: Paradise Township, Adams County, PA. 3. Date of Separation: July 1, 2006 4. Date Action Commenced: September 11, 2006 a. Amended Divorce Complaint filed on February 6, 2007 5. Issues Raised: a. Divorce Grounds: indignities/adultery b. Equitable Distribution c. Alimony d. Alimony Pendente Lite e. Counsel Fees, Costs and Expenses II. INCOME 1. Husband is retired from the United States Post Office and is currently employed at auto Sun Roof and Harrisburg Auto Auction. 2. Wife is a homemaker. III. ASSETS: A. Real Property 1. Marital Residence- to be appraised. 2. Lot adjoining property, separately deeded- to be appraised. 3. See attached Preliminary Asset list. B. Retirement Plaintiff: 1. None and only receives $ 41.00 per month Social Security. Defendant: 1. U.S. Postal Service. In pay status 100% marital asset. 3. Vehicles. 1. Dodge Caravan 2. Oldsmobile Alero 3. Buick LaSabre 4. Buick Electra 225 (mint condition) 5. Chevy Conversion Van 6. Dodge Dakota Truck 7. 64 Ford Galaxy 500 (classic car) Values to be determined D. Personal Property associated with the house. 1. Household contents. 2. Extensive Toy Collection: estimated purchased value in excess of $ 247,000.00 per Husband's partial records. See attachment Ruhland Asset List 2007 updated November 30, 2007 F. Life Insurance 1. To be determined III. MARITAL PROPERTY TRANSFERRED A. Husband sold a 1994 Dodge Dakota pickup truck, May or 2007, Kelly Blue Book value $ 4,500.00. B. Husband's IRA; Husband cashed in an IRA in the amount of $ $47,432.42 on May 8, 2007. C. Husband withdrew $7,432.45 from DWS Scudder account No. 404299028 on May 8, 2007. IV. MARITAL DEBT- NONE V. WITNESSES A. Expert. 1. Real Estate Appraiser: To be determined. B. Fact: 1. Marie L. Ruhland 2. Glen A. Ruhland as on cross 3. Glenda Sites 4. Additional witnesses to be determined. VI. PROPOSED RESOLUTION A. 50% distribution of Husband's retirement via QDRO (all marital asset) B. 60/40 Asset distribution of remaining assets. Husband to maintain health insurance coverage for wife. Husband to reimburse wife for counsel fees, costs and expenses. C. Alimony Pendente Lite and Alimony for life. Respec lly Submitted, JOAN HARRISON CLOUG Date: '-4 By: _/- i Attorney I.D. No. 36461 / I 3820 Market Street Camp Hill, PA 17011 Telephone No. [7171 737-5890 Attorney for Plaintiff Marie L. Ruhland Updated 11/30/2007 Ruhland Asset List Item Amount 11 Marie wants 3BR Ranch house w/2 car garage, full basement, outside lar a garage $ 200,000 Side lot deeded separately (min value) $ 50,000 Dodge Caravan $ 4,000 $ 4,000 Oldsmobile Alero $ 2,000 Buick LaSabre $ 2,000 Buick Electra 225 (mint condition) $ 1,000 Chevy Conversion Van $ 2,000 Dodge Dakota Truck This was sold (KBBValue) $ 4,000 64 Ford Galaxy 500 (Classic Car) $ 6,000 John Deere 445 Garden tractor (2002/newer) $ 4,000 (with front end loader, mower deck, blower... ect) i 3 John Deere 300 Lawn tractors with accessories (blade, blower, mowers) $ 2,000 1 1970's Deere Lawn tractor (include with above price) Spare parts for Deere tractors/ frame $ - Tools, tool boxes loaded with tools (garage full of stuff too much to mention) $ 1,000 Manual fire machine & balancer, fire changing supplies $ 50 2 compressors ; $ 50 a 2 Honda Mopeds _ $ 200 Welder & tanks $ 50 Collector pedal tractor(s) (antique) "`Book value over 1200 each $ 600 Generator $ 200 _ Lawn Sweeper $ 50 Spare parts for classic cars/hubcaps, fender skirts ..... ect $ 100 Pressure washer $ 50 2 push power mowers : $ 50 Computer system w/operatin software (already removed from house) $ 250 Toro 12hp two stage snow thrower (Glen tried to sell for 1 K) $ 500 Ext ladders $ 100 Trailer $ 200 Car tow trailer _ $ 300 Washer & Dryer (less than 2 yrs old) j $ 300 _ i Toys bought 2006 + 2007 (minimum)(copies of some reciepts for these) $ 3,000 Various guns (4)? Could be more $ 400 ', To tractors, cars, banks, Hess trucks, ....too man to mention $ 2007000 (see list provided by Glen on CD, the addition of one section to his value is over 240K) Master Bedroom - Cedar hand crafted furniture f $ 200 (Bed, 2 dressers, large mirror, chifferobe, chest) 1st Guest room Bedroom set $ 200 $ 200 Front Bedroom furniture (not a set mixed pieces) $ 100 $ 100 Kitchen table & chairs worn hard $ 25 $ 25 Page 1 of 2 Updated 11/3012007 Ruhiand Asset List Item Amount Marie wants Buffet hutch in Dining Room $ 800 $ 800 Comer cabinet in Dining Room $ 200 $ 200 2nd comer cabinet in Dining Room $ 200 Dining room table and chairs $ 300 $ _ 300 Sewing machine Living room Sofa and chair $ $ 50 100 $ $ 50 100 2 Blue recliner chairs $ 30 $ 30 TV in living room $ 50 $ 50 Entertainment center $ 50 $ 50 3 Misc tables/li hts living room $ 100 , $ 100 Comer curio closet living room $ 100 $ 100 Pictures other items on walls $ 100 $ 100 Vacumn Cleaner $ 50 $ 50 2 sets of dishes $ 300 $ 300 Cut glassware set $ 100 $ 100 various sundry nick nacks (most purchased at yard sales) $ 100 $ 100 Downstairs sofa and chair ( & other furniture items) . $ 30 , Sun porch TV $ 50 $ - Sun porch TV entertainment center $ 50 $ 50 Other porch furniture $ 50 $ 50 Outside furniture $ 50 Outside nick nacks $ 25 $ 25 Antique crocks other misc in basement (Chess set) $ 100 $ 100 Grave plots ; $ 1,500 $ 1,500 Investments i Mellon is 24,300 i US Savings Bonds (including 2 awarded bonds to Marie) $ 84,344 Soverein Bank / Rite Aid stock _ $ 700 Members First CD $ 10,900 Sub Total $ 120,244 Other - His name Scudder This was cashed out by Glen Joint - DWS Scudder -- $ $ m 134 3000? Her name Scudder Awarded to Marie _ $ 27,000 Total $ ?}© Total 1/2 f Items Wanted from Marital pro rty Taken off pe i i $ ,48U) U) $ 8,480 II F ;$ $- ?$ - - Page 2 of 2 VERIFICATION I, Marie L. Ruhland, hereby verify and state that the facts set forth in the foregoing pleading 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. Section 4904 relating to unsworn verification to authorities. DATE: 7 Marie L. Ruhland CERTIFICATE OF SERVICE /A AND NOW, this ? day of , , u c• - i , 2008, I hereby verify that I have caused a true and correct copy of the foregoing document, Pre-Trial Statement of Marie L. Ruhland, to be placed in the U.S. mail, first class, postage prepaid and addressed as follows: Glen A. Ruhland C/O Lesley J. Beam, Esquire Kope & Associates, LLC 4660 Trindle Road Suite 201 Camp Hill, PA 17011 JOANNE HARRISON CLOUGH-I.C. By: Attorney I.D. No. 36461 `-' 3820 Market Street Camp Hill, PA 17011 Telephone No. [717] 737-5890 Attorney for Plaintiff r c.? f? :C? a ? l KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com Attorney for Plaintiff MARIE RUHLAND, Plaintiff, vs. GLEN RUHLAND, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5297 : CIVIL ACTION - LAW : IN DIVORCE STIPULATION FOR PARTIAL EQUITABLE DISTRIBUTION IN LIEU OF SUPPORT AND NOW, this ? day of , 2008, Marie Ruhland (hereinafter referred to as "Plaintiff") represented by Joanne Harrison Clough, Esquire, and Glen Ruhland (hereinafter referred to as "Defendant") represented by Lesley J. Beam, Esquire, having reached an agreement to mutually settle and resolve the issue of support of Plaintiff through a partial equitable distribution in the above-cited divorce action, hereby agree to legally obligate themselves to the terms of the following Agreement: WHEREAS, Plaintiff filed a Complaint for Support for herself on January 9, 2008; WHEREAS, both parties appeared for a support conference at the Cumberland County Domestic Relations office on January 30, 2008; WHEREAS, the parties orally agreed to the terms of this agreement at said conference, and indicated to the conference officer, R.J. Shadday, that the complaint for support would be withdrawn as a consequence of this agreement; WHEREAS, Defendant has retired from his position at the U.S. Postal Service and has begun receiving his pension benefits, said benefits being considered a marital asset subject to equitable distribution; WHEREAS, the pension benefits constitute the vast majority of Defendant's income, as Defendant maintains only part-time employment as a retired person; and WHEREAS, the parties have reached an agreement regarding support of Plaintiff, are desirous of avoiding further legal proceedings to provide for the immediate support of Plaintiff and intend for this Stipulation to be entered as an Order of Court: NOW, THEREFORE, it is hereby agreed to and stipulated by the parties as follows: 1. Upon receipt of his pension each month, Defendant shall pay to Plaintiff one-half (Y2) of the net monies received, said monies to be paid to Plaintiff by directly depositing the funds into Plaintiff's checking account upon receipt of the monies. Defendant has already made such payments to Plaintiff in February and March; 2. Plaintiff and Defendant currently maintain a marital residence. Plaintiff agrees to reimburse Defendant for one-half (%2) of the bills for this residence, including but not limited to taxes, electricity, gas, oil, sewer, water, cable, telephone, and all other bills that would be considered bills for the maintenance of this home and property. Defendant shall make the bills available to Plaintiff, who will pay one-half (%2) of the total payment owed no later than one month after the payment has been made by Defendant, and no later than two weeks after said bills have been forwarded to Plaintiff for their review. 2 . IL 3. The effective date of this Order shall be February 1, 2008. 4. Plaintiff agrees to withdraw her complaint for support through Domestic Relations, PACSES No. 92108535, and shall request that the de novo support hearing scheduled for April 9, 2008 at 8:30 a.m. be cancelled. 5. The parties stipulate and agree that the terms and conditions of this Stipulation shall be entered as an Order of Court. 6. The parties agree that the terms of this Stipulation shall be binding as an Order until such time as the parties reach a final agreement dissolving the marital estate (otherwise known as a Marital Separation Agreement or MSA), or until a recommendation has been made by the Divorce Master of Cumberland County in accordance with the state and local Rules of Civil Procedure. WHEREFORE, the parties so stipulate on the date first written above. KOPE & ASSOCIATES 4660 Trindle Road, Suite 201 Camp ill, PA 17102 Tel one,f ID 761-7573 J(Beam, Esquire v for Defendant Joanne Harrison Clough, Esquire 3820 Market Street Camp Hill, PA 17011 Telephone (717) 737-5890 fi „ Joanne Harrison Clough; Attorney for Plaintiff Glen Ruhland 2725 Lisburn Road Camp Hill, PA 17011 Defendant Marie Ruhland 2725 Lisburn Road Camp Hill, PA 17011 Plaihtiff 3 "If 08 -13T u $ co 5 co MARIE L. RUHLAND, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-5297 GLEN A. RUHLAND, : CIVIL ACTION -LAW Defendant : IN DIVORCE PLAINTIFF MARIE L. RUHLAND'S PETITION FOR CONTEMPT OF COURT'S AUGUST 8.2007 ORDER AND NOW, this _Qtay of July, 2008, comes the Petitioner Marie L. Ruhland, by and through her attorney, Joanne Harrison Clough, Esquire, and files this Petition for Contempt of Court and in support thereof avers as follows: 1. Plaintiff is Marie L. Ruhland, an adult individual who currently resides at 2725 Lisburn Road, Camp Hill, PA, Cumberland County, Pennsylvania, 17011. She is represented by Joanne Harrison Clough, Esquire. 2. Defendant is Glen A. Ruhland, an adult individual who currently resides at 41 Hazel Circle, Mechanicsburg, Cumberland County, Pennsylvania, 17050. He represented by Attorney Lesley Beam. 3. On April 20, 2007, Petitioner/Plaintiff wife filed a Petition for Special Injunctive Relief to prevent the dissipation of marital assets. 4. On April 26, 2007 the Court issued a Rule to Show Cause which specifically directed that "no marital property shall be sold, removed or transferred by Defendant until further Order of Court". 5. A hearing was held on said Petition on August 8, 2007. At said time of the hearing on this Petition, the Court entered an Order specifically directing in part as follows: 1. "An Order is now entered preventing either party from removing, transferring, selling or otherwise disposing of any marital asset, regardless of whether jointly or individually titled, without prior agreement of the parties or Court approval." A true and correct copy of said Order is attached hereto as Exhibit No. 1. 6. Defendant has violated the August 8, 2007 Order of Court as follows: a. On or about June 1St, 2008, Defendant Glen Ruhland cashed and transferred a Certificate of Deposit with a value of $11,234.01 (which was all acquired during the course of the parties marriage and therefore marital property) to the parties' joint Member's 1St Federal Credit Union account. b. Said Certificate of Deposit was titled in both names as Glen A. Ruhland and Marie L. Ruhland and could not be surrendered to Defendant Glen A. Ruhland without Plaintiff Marie L. Ruhland's signature, but Defendant could and did transfer said Certificate of Deposit proceeds to the parties joint savings account without Plaintiff Wife's knowledge or permission. c. On June 2, 2008, Defendant Glen A. Ruhland withdrew the proceeds of the 30 month Certificate of Deposit in the amount of $11,234.01 from the parties' joint savings account with out Plaintiff Marie L. Ruhland's knowledge or permission in direct violation of this Court's Order of August 8, 2007. Said joint account is titled in Glen A. Ruhland or Marie L. Ruhland's name so the monies could be withdrawn without Plaintiff Wife's signature. d. On June 2, 2008, Defendant Glen A. Ruhland also withdrew the nominal remaining monies in this joint Member's First account and closed said account without Plaintiff Marie L. Ruhland's knowledge or permission for a total withdraw of $11,279.01 in direct violation of this Court's August 8, 2008 Order. A true and correct copy of the Members l St Statement showing said transfer of the 30 month Certificate of Deposit and the withdrawal of monies is attached hereto as Exhibit No. 2. Plaintiff did not consent to the transfer of the Certificate of Deposit or said withdraw of monies by Defendant Glen A. Ruhland. 7. Counsel for Plaintiff contacted Defendant's attorney's office on July 3, 2008 to notify them of this illegal action by Glen A. Ruhland and opposing counsel has failed to return said emergency phone call. 8. The Court did not enter an Order permitting the Defendant to withdraw said monies. 9. Petitioner/Plaintiff Marie Ruhland is of the belief and therefore avers that Defendant Glen Ruhland may have in fact dissipated numerous additional marital assets that she has not discovered as of this date and believes she may be irreparably be harmed if said dissipation is not stopped. 10. Petitioner/Plaintiff Marie Ruhland has been caused to incur additional counsel fees, costs and expenses in a minimal amount of $750.00, as a direct result of Defendant Glen Ruhland's failure to abide by this Court's Order of August8, 2007 that she would not have otherwise incurred but for his behavior in violating this Court's Order and his behavior in attempting to dissipate marital assets and/or hide assets from her. 11. This matter was previously assigned to Judge Oler. 12. Opposing counsel is believed to not concur in this Motion since she failed to return a telephone call from Plaintiff's counsel where her staff was informed of the unauthorized withdraw of funds and Plaintiff's intention to file this Petition for Contempt. WHEREFORE, Petitioner/Plaintiff Marie Ruhland respectfully requests this Honorable Court schedule a hearing on this Petition and hold Defendant Glen Ruhland in Contempt of Court of the August 8, 2008 Order and grant the following relief: a. Direct Defendant Glen Ruhland to disclose to Petitioner and her counsel within 48 hours of this Court's Order a complete accounting of the disbursement of the $11,279.01 he withdrew from said Certificate of Deposit; b. Remove Glen A. Ruhland as an authorized signature or authorized person on any bank account, Certificate of Deposits, Retirement, Savings Bonds, or other account that holds marital funds whether jointly or individually titled and enter any other Order necessary to prevent Defendant Glen A. Ruhland from accessing or liquidating any other marital asset without obtaining written permission of Plaintiff Marie L. Ruhland or an Order of Court. C. Order Glen A. Ruhland to pay for all of Marie Ruhland's reasonable counsel fees, costs, and expenses she incurred in the filing of this Petition for Contempt and/or otherwise incurred as a result of his behavior; d. Award an immediate distribution of marital assets to Plaintiff Marie L. Ruhland in the amount of $11,279.01; Respectfully Submitted, JOANNE HARRISON CLOUGH. PC Dated: 'I - \a- ob Attorney I.D. No. 36461 24 N. 32nd Street Camp Hill, PA 17011 (717) 737-5890 Attorney for the Plaintiff CERTIFICATE OF SERVICE I, Joanne Harrison Clough, Esquire, do hereby certify that on this date I served a copy of the foregoing document by United State Mail, first class, to the following individual set forth below: Lesley J. Beam, Esquire KOPE & Associates, LLC 4660 Trindle Road Suite 201 Camp Hill, PA 17011 Date: 11 " \ Z /- A Attorney ID No. 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Defendant MARIE L. RUHLAND, Plaintiff v GLEN A. RUHLAND, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 06-5297 CIVIL TERM IN RE: AGREEMENT OF THE PARTIES ORDER OF COURT AND NOW, this 8th day of August, 2007, upon consideration of Plaintiff's Petition for Special Injunctive Relief To Prevent Dissipation of Marital Assets, and of Defendant's Response to Rule To Show Cause and Answer to Plaintiff's Petition for Special Injunctive Relief, and pursuant to an agreement reached in open court on today's date by counsel in the presence of the parties, it is ordered and directed as follows: 1. An order is now entered preventing either party from removing, transferring, selling or otherwise disposing of any marital asset, regardless of whether jointly or individually titled, without prior agreement of the parties or court approval. 2. Notwithstanding the foregoing, husband shall retain the proceeds from the DWS Skudder account in the amount of $47,432.45 he liquidated on May 8th, 2007, as a partial equitable distribution award in this divorce action. 3. Wife shall also receive her DWS Skudder account with a June 30th, 2007, account value of $27,976.35 and two $10,000 series EE savings bonds numbered X2171090EE and X2171091EE, each with a value of $11,448, which are currently in husband's possession as a partial equitable distribution order to wife. Husband shall immediately transfer the two $10,000 savings bonds to husband's counsel, and the respective attorney shall arrange the transfer of the bonds to wife. 4. In consideration of the parties reaching this agreement today, wife agrees to not file the Petition for Contempt that she prepared, and will not seek a finding of contempt against husband for any other pre-dissipation of assets that has occurred from the date of filing of wife's Petition for Special Relief. Joanne Harrison Clough, Esquire 24 N. 32nd Street Camp Hill, PA 17011 For Plaintiff Le ley J. Beam, Esquire 660 Trindle Road suite 201 Camp Hill, PA 17011 For Defendant :mae By the Court, o o? 2725 USBURN RD CAMP HILL PA 17011 Page : 1 of 2 Your current Member Loyalty Reward level is Silver With zero origination fees, lower interest rates and flexible repayment options, it's easy to sea why our new student loan product is a better way to pay for college. Visit http:iimembemistatudentehoice.org for more information. *'Xomv oc C. (26id &ka SAVINGS ACCOUNTS 00 - REGULAR SAVINGS G1 en a?6W 0u+sav? 00110 Tnn"ClOn 92291 ft Additions Subs Balance Mer 25 Blabmne Fa?mwd 25.00 :Ju D eposit Transfer From Share 47 11,254.01 1.279.01 TRANSACTION DATE - 06/0112006 n 02 Withdrawal by Check 11,279.01- 0.00 REOU AR $4 VAVGS Ckwd _ '•'7bb /I the Ass/ swat `paeo-Ow ire mwJiw on #* ponOrwr ••• Ppaase X06167 ft Air/ S&AWYWd Aar fipr A*Vfft pWpoSW ••• CERTIFICATE ACCOUNTS 46 - 30 MONTH CERT Data Tram ufto Qoewbtion Addltions &ftedlons Balance Mar 25 awmar Fcvcmd 566.06 Mar 31 Deposit Dividend 4.8909E 2.31 558.37 A%%W Pb mna gie Y6ufd Earned 5 W0 ftm WIOIIZ08 W131120 M Apr 30 Deposit Dividend 4.89096 2.24 560.61 A&vAW Plvicer Wqe YbwPd Em"ed 4.910 ftm 0410112008 dhrou,0h 04/31012VLV May 28 Deposit Dividend 4.89096 2.03 562.64 Arretrsr Pawnidrge YAW Fanned S.VXX 0»m 0510flZIM drrn " 05127121UA!! Renewed at 2.91D%to mature 11128110 May 2B 1Nithdrawei by Check 582.64_ 0.00 3a A40AMf f;ERT Obsed 7M a No drAW sbu wnW p ww*W M vrirslan on 0* po4tvr ••• Aloes reams filer *ae/ s&A wrant for Am repaift pwposes "" --- Continued on folovft page --- L'd L9L0-Li?-LLL seoinieg BUY60WOU3 130 89910 90 00 inf „ul'03 08 07:57a CET Engineering Services A e MEMBERS V FEDERAL CREDIT LTNION Send inquires to: 5000 Louise Drive PC Box 40 MaChaniesbury, PA 17055 www.msmberst sLorg Main Switchboard: (800) 283-2928 EZ Call: (717) 897-4372 or (800) 283.4372 TDD: (717) 897-5312 or (800) 283-2328 eat 3312 TolaBraneh: (800) 237-7288 4373 1 AV 0.329 8745-4373 t IM11111 111111 Mill 11111111111 11 11111111111111A ?- GLEN A RUHLAND MARIE L RUHLAND 2725 LISBURN RD CAMP HILL PA 17011 c o? 717-441-0161 p.2 Statement of Accounts Mar 25, 2008 thru Jun 24, 2008 Account Number: 277092 ,.,., Account Balances at a Glance : Checking : 0.00 Savings : 0.00 Certificates : 0.00 Loans: 0.00 Money Management : 0.00 Page : 1 of 2 Your current Member Loyalty Reward level is Sffver With zero origination fees, lower interest rates and flexible repayment options, it's easy to see why our new student loan product is a better way to pay for coNege. Visit http:l m mberslst.studentehoice.org for more information. pcea,.??G?ceaQde?- Date Tranead n D-n- ' ion Ad?fons subtacIlions_ Afar 25 awsa s Fclrwsad 25.00 Deposit Transfer From Share 47 111,254.01 1,279.01 TRANSACTION DATE - 0610112006 Jun 02 Withdrawal by Check 11,279.01- 0.00 REGfJO(?IR 34MWG'S Gdeed "•71a+k ,[r ft #W 86dWrbint pnear+ V*W #bWn8ibn an OW pvoo wr w- - - - • •• PMAW rsblh 0* ffAW allibrnant abr tatar r+ep I ft pffposas • •• CERTIFICATE ACCOUNTS 46 - 30 MONTH CERT Date Traneoron . 02KIlidgn Additions aftrG Balance Afar 25 FaMard 566.06 Mar 31 Deposit Dividend 4.6909E 2.31 566.37 Armue/ Plsrl?rakgs )-x W Eared 5. XLW 8cvri 031011ZW 00096 013112M Apr 30 Deposit Dividend 4.6M 2.24 560.61 AMNAW PJeraelte YON toned 4 SM ft m OW/W/2= r MVh as15o12VW May 26 Deposit Dividend 4.88096 2.03 562.64 Aa> WRI f49v mob9o Yh d Emne4r S. 010 /ivm W/01/200 Onargpb 051271ZW Renewed at 2.910%to mature 11/20110 May 28 Withdrewof by Check 862,64- 0.00 30 MONTH CERT CAXW •'"7i?l?fs ds lhs A iW siAerr err tng Ihtlrirr bra orf i?air9 puiootact••• AW plrnea .{. ? ? / *00 Abase v --- Continued on buawing page --- SAVINGS ACCOUNTS Gjen CM5 Qx+SAYI 00 - REGULAR SAVINGS Jul •03 08 07:53x. CET Engineering Services Send Inquires to: St 5000 Lourse Drive AO Box 40 Mechaftsbuig, PA 17055 www.rmmbsrs1 at0r9 Main Swhchbotrd: (800) 283.2328 EZ Wh (r17) 687-4372 or (800) 288-4972 TDD: (717) 697-5312 or") 283.2328 ate. 5392 Telowaneh: (800) 237-7288 MEMBERS St FEDERALCREDrr UNION N? o? o? 4373 1 AV 0.324 8745-4373 If 1111ln1lllu„1111,11111111411414111111slu11141*1tlnllnl GLEN A RUHLAND MARIE L RUHLAND 2725 LISBURN RD CAh9P HILL PA 17011 717-441.0161 P.1 Statement of Accounts Mar 25, 2008 thru Jun 24, 2008 Account Number: 277092 Account Balances at a Glancae : Checking: 0.00 Savings: 0.00 Certificates : 0.00 Loans: 0.00 Money Management : 0.00 Page : 1 of 2 Your current Member Loyalty Reward level is Silver With zero orlonation fees, lower interest rates and flexible repayment options, It's easy to see why our new student loan product is a better way to pay for college. Visit http:tlmemberslst.studer*choice.org for more information. CD WAD 01 L JL `N? ara?+#to G? c?Vdecok- Date TMNAcft R2K& ion dlh" subhacm 9aance AArr 25 aftow FOAWW 25.00 DeposiE firanafer From Share 47 11,264.01 ".1'1.279.01 TRANSACTION DATE - 06!01/2008 Jun 02 Withdrawal by Check 11,279.01- 0.00 ASM"R S4 VJ VS Cktssd "•7ft b 06 *MW sArkrndw Pr Ml ntv i*NM W on OW produd••• Pbm mAsh OW SW sAWWmW for Aw nwini ft PAPmes r?r CERTIFICATE ACCOUNTS 46 - 30 MONTH CERT Data Thyawtim n AaMns Subtractions 1801w e" Aftr 25 Alebwwee Pv-s o..d SAVINGS ACCOUNTS G1ein ca5 ked Qw+.54L?t 00 - REGULAR SAVINGS Jul *03 08 07:57a CET Engineering Services st Send Inquires to: tulein SwItett" rd; 1800] 283.2328 l?500Sm 40 Loulso Drive EZ CMI: ? Boz ? (717)8.97-4s72 or (800) 283.4372 fOwhsnksburg, PA 17085 TOM (717) 697-5312 or (800) 283-2328 ext. 5312 MEMB?FAS1R www.mernbomIst.org TNeBnnah; (800) 237 7288 717-441-0161 p.1 Mater 25 , 2008 thru Jun 24 , 20000 0,145-4"' Account Number : 277092 Page : 2 of 2 47 - 30 MONTH CERT Date Transaction !. eemolion Arkflions Subtractions Bellows Mar W BA mce Forward 11,116.89 Mar 31 Deposit Dividend 4.89D% 46.17 11,163.16 AnnuN Pisrtaerrtsgs YAW Earned 5.00M lfnrrr 0310112008 ft vufi 03131121aGIB -- * Apr 30 Deposit Dividend 4.8900/6 44.87 11,206.03 v Annual Pi3rra ofte ya(d Earned 5.0101x ham 04101121A0t3 Amg96 0413012UM May 31 Deposit Dividend 4.MM h 05/30/MX Annual P YAW E d 5 OWX lham 05/01/ZW 11not c & 45.05 19,253.06 .. ff ge w ame . 4 Renewed at 3.01D%to mature 11/29/10 C May 31 Deposit Dividend 3.D10% 0.93 11,254.01 bile Annual AwWA& 9 YaW 6emred 3.0WX #vm 0513112008 MA74 ih 01513112WO *iM Jun 02 Withdrawal Transfer To Share 00 11,254.01- 0.00 TRANSACTION DATE - 06/01 /2008 30 MONTH CFAT Gbmed "17ft ir the Iklte/ sfblbem W piresw*V 61ir6rrrw#m an ft product'.. ••• Paeese reWi A& AW statement for Arc AWvrthp /x4pasas "' YTD SUMMARIES TOTAL DIVIDENDS PAID 00 REGULAR SAVINGS 0.00 46 30 MONTH CERT 11.02 47 30 MONTH CERT 225.84 Total Year To Date Dividends Paid NOTE : Total includes closed shares 236.86 Don't forget about our new Member Loyalty Rewards Program. The more products you have with us, the more benefits you'll receive. Ask an associate for details or visit our website at www.memberslst.org for details. m X JUL 1 X 2008 MARIE L. RUHLAND, Plaintiff v. GLEN A. RUHLAND, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5297 CIVIL ACTION -LAW IN DIVORCE RULE TO SHOW CAUSE AND NOW, this aLday of July 2008, upon review of the attached Plaintiff Marie Ruhland's Petition for Contempt of Court's August 8, 2007 Order, A Rule is hereby issued against the Defendant. Glen A. Ruhland, to show cause, if any, why Plaintiff's Petition for Contempt of this Court's August 8, 2007 Order should not be granted and why Defendant shall not be held in contempt of Court and why the relief requested should not be granted. S C_ ? e Rule returnable vvM in fd2t, of eise, d 2 c ZJ lI i? ooh' t4 ?? . J r 4fu J.Ad'j" • 7 Aftv ALW 91 =9 V 91 inr o0oz - 1301-0211k MARIE L. RUHLAND, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW GLEN A. RUHLAND, : Defendant NO. 06-5297 CIVIL TERM IN RE: CONTEMPT ORDER OF COURT AND NOW, this 21St day of May, 2007, upon consideration of Plaintiffs petition for contempt, the hearing previously scheduled for August 11, 2008, is rescheduled to Thursday, October 30, 2008, at 1:30 p. m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, .Ao me Harrison Clough, Esq. 24 N. 32nd Street Camp Hill, PA 17011 Attorney for Plaintiff ,,Kesley J. Beam, Esq. 4660 Trindle Road Suite 201 Camp Hill, PA 17011 Attorney for Defendant :rc 4 n ell ?'?tk IsJ Ti(" MARIE L. RUHLAND, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW GLEN A. RUHLAND, Defendant NO. 06-5297 CIVIL TERM IN RE: CONTEMPT AMENDED ORDER OF COURT AND NOW, this 4`h day of August, 2008, the prior order of court dated May 21, 2007, is hereby amended to reflect a correct date of July 21, 2008. In all other respects, the prior order shall remain in full force and effect. BY THE COURT, a J { J. Wesley Oler,Tr., J. Joanne Harrison Clough, Esq. 3 820 Market Street Camp Hill, PA 17011 Attorney for Plaintiff ftd vt/esley J. Beam, Esq. J 4660 Trindle Road Suite 201 Camp Hill, PA 17011 Attorney for Defendant :rc _o f 1 MARIE L. RUHLAND, Plaintiff VS. GLEN A. RUHLAND, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 5297 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this day of , 2008, the Plaintiff, Marie L. Ruhland, having passed away on September 6, 2008, and no grounds for divorce having been established pursuant to 23 Pa.C.S.A Paragraph 3323(g), and therefore, there being no matters pending before the Master, the appointment of the Master is vacated and all matters pending in this divorce action are terminated. BY THE COURT, cc: Joanne Harrison Clough Attorney for Plaintiff Lesley J. Beam Attorney for Defendant ` /? // L?' 3 . 1 l . ?,. CJ? LOCAL REGISTRAR'S CERTIFICATION OF DEATH WARNING: It is illegal to duplicate this copy by photostat or photograph. This is to certify that the information here given i correctly copied from an original Certificate of Deat duly filed with me as Local Registrar. The origina certificate will be forwarded to the State Vita Records Office for permanent filing. Z?SEPA9 I _ Local str --_.._..... n_.-Das..-_. Fee for this certificate, $6.00 P.14805658 Certification Number MW14 f*V U= COMMONWEALTH OF PENNSYLVANIA • DEPARTMENT OF WEALTH • VITAL RECORDS FFEI TY1RA"'RW T CERTIFICATE OF DEATH BLACK Pa (See instmadons and exampbs on rowras) 1.1.b.b of DowmW.L mnp, WK oft) 23.b 3.gMW3.a.eyWftW a. Drs of Dab PAWN dry. y- Marie L. Ruhland Female 170 _ 30 - 2902 September 6, 2008 . S. AV. DAa Bantry) urANt lbdPt 3.0dd8.b 7. Biepho.l bm.M1.« &R-dD0* «r1 PA ?' otww?.. W.r mom. 04/0 /1938 Jennerstown 70 , YN Dnprw. 0-'WwP ODDA 1p o woman Dnaa.c. 0abw.3P.ay b. Corry"Dam K. Cby. Bao, TV* a D. M ea Featly N- N•d Wilton, OW dwd wd Naw er 9. Wr D.W" a fb.W 0dph7 ND Yr 10. Fbw And=11er. Bata WA. ft. Cumberland Middlesex 2lap. , Claremont Nursing & Rehabilitation ' UW, f-140* White ii.D.b.ddw. U" aWant .rr ofWNWo w.wrolar mendA 12 VA. D.ad ~ber f3.DwdMa Etlnrto. (3Wd/i'?i' 9o• -WA" 14. NNW 9Ya MK.K NVW W.W, 13. S11'" 43Pwr(dWb. Per mdawl rWrel v??p??ypy I yip a'.y.. Tim HoAaM r O u.s.amWtlFawn y?^.r (P1s) G1yly..lld «Sr) D?W (SP.dPA e Ova Mw Married Glen A. Ruhland It DaodaftM ftAS7a.(9ba. dT l MM..aaa.pm4) D.rdoft Dd Dx.em PA Middlesex TW 29 Eastwood Drive AdW ROSd.nr 17.. BW p. 17a ®na DbdW (;..ee _ Tw. PA 17315 Carlisle 17b.caKdy CLEmberland 17a0 ?? d.la^ , City; Bap K Fart Wft(FW. nWft, ML ft) Jahn Keller Brantley 12. Marr.Nwr PWL ddd.. drdMWwe.) Mary Margaret Keenen tot WMW0N.N.{Ty"1P" Glendalene M. Sites WA NW.W. MOVAddwwMbK ybKa,ad, eod.) 29 Eastwood Dr., Carlisle, PA 17015 2fa M.a.dd DhP..rrA f ?CAMWaI ?Dwabm yb s "d D a ? ° 2b. d11d[YprB.A Prorl.ely.l..r1 2h. PlpdBipaerPWaanaMly,wa.aayadWr Pha1 ' 21Q 1m0eP Pay?/W^$ iWVW4 .Ab oel Ne. "r ° ?` i tlfl : D 09/11/2008 Trinity Roth s Cemetery Spring Grove PA 17362 M w arPW o bw• r....Lr wd w , UL BwMe. rwrfd Y20. Lbw-. 22p. 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Name ant Mdrsd?eron aDabieem 2T type: 31 Rm ' 1 / .y ./4 / 17 ! I 1 7 1 1 / J 39. Drr Fftd PA n . day. tan ?ftAWS' N , ---v _ c7( 4+ 10 / L 1) DC /!ia & oe>d (bpg- Qp 6AVt4 RA 1 76 2 J_,/ .b. 0 11 1?5 7/ 4/ MARIE L. RUHLAND, Plaintiff V. GLEN A. RUHLAND, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-5297 CIVIL TERM IN RE: PLAINTIFF MARIE L. RUHLAND' S PETITION FOR CONTEMPT OF COURT'S AUGUST 8, 2007 ORDER ORDER OF COURT AND NOW, this 26 b day of September, 2008, upon consideration of the attached letter from Joanne Harrison Clough, the hearing previously scheduled in the above matter for October 30, 2008, is cancelled and Plaintiffs petition is deemed moot. BY THE COURT, 'esley Ctd, Jr., J. Joanne Harrison Clough, Esq. 3 820 Market Street Camp Hill, PA 17011 Attorney for Plaintiff Lesley J. Beam, Esq. 4660 Trindle Road Suite 201 Camp Hill, PA 17011 Attorney for Defendant 4- :rc P; ? :Z d 9Z d3S BOOZ Rfb a t1,t 1::" H1:10 r JOANNE HARRISON CLOUGH, PC ATTORNEY AND COUNSELOR AT LAW 3820 MARKET STREET CAMP HILL, PENNSYLVANIA 17011 717.737-5890 TELEFAX 717.737.5892 Joanne Harrison Clough, Esquire Email: jhclough@a,comcast.net September 24, 2008 The Honorable Judge J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: Ruhland v. Ruhland To the Honorable Judge Oler: My client Marie Ruhland passed away on September 6, 2008. Please cancel the hearing scheduled for October 30, 2008 at 1:30 as it will no longer be necessary. JHC/cll Enclosures Sincrely, gh SEp ? Joanne Harrison Cl 5 2008