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HomeMy WebLinkAbout02-2426PATRICIA ANN HASLAM, Plaintiff VS. MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 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 foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 PATRICIA ANN HASLAM, Plaintiff VS. MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. PATRICIA ANN HASLAM, Plaintiff VS. MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, PATRICIA ANN HASLAM, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is PATRICIA ANN HASLAM, an adult individual who currently resides at 42 Wheatfield Drive in Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is MICHAEL F. HASLAM, an adult individual who currently resides at 42 Wheatfield Drive in Carlisle, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 27 October 1979 in Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I -- IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT II -- EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as martial property. COUNT III -- ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of the Plaintiff and pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV -- ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT V -- COUNSEL FEES AND EXPENSES 15. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in this litigation of this action. Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). PATRiCIA ANN HASLAM PATRICIA ANN HASLAM, Plaintiff VS. MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2426 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE I hereby enter my appearance for the Defendant, Michael F. Haslam, in the above- captioned action. I acknowledge receipt of a true and correct copy of the Complaint in Divorce filed in the above action on behalf of the Defendant. McNees Wallace & Nurick, LLC Attorney for Defenda_nt _ Supreme Court ID # 100 Pine Street Harrisburg, PA 17101 PATRICIA ANN HASLAM, Plaintiff · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL F. HASLAM, . Defendant : NO.02-2426 CIVIL TERM CIVIL ACTION - LAW PETITION OF MICHAEL F. HASLAM FOR SPECIAl RELIEF REQUESTING EXCLUSIVE POSSESSION OF MARITAL RESIDENCE PURSUANT TO § 3502(c) OF THE DIVORCE CODi AND NOW, this 11th day of July, 2002, Petitioner, Michael F. Haslam, by and through his attorneys, McNees Wallace & Nurlck LLC, files the within Petition for Interim Exclusive Possession of Marital Residence, and in support thereof, avers as follows: 1. Petitioner Michael F. Haslam (hereinafter "Petitioner") is Defendant in the above-captioned divorce action· Petitioner and the parties' children currently reside at 42 Wheatfield Drive, Carlisle, Cumberland County, Pennsylvania, the "marital home." 2. Respondent Patricia Ann Haslam (hereinafter "Respondent") is Plaintiff in the above-captioned divorce action. Plaintiff currently resides at 42 Wheat'field Drive, Carlisle, Cumberland County, Pennsylvania, the "marital home·" 3. The parties hereto were married on October 27, 1979 in Camp Hill, Cumberland County, Pennsylvania. 4. The parties are the parents of the following unemancipated children who reside at the marital home: (1)Aaron M. Haslam, born November 19, 1984, (2) Carly A. Haslam, born August 4, 1987, and (3) Annie P. Haslam, bom January 22, 1990. 5. On May 17, 2002, Respondent filed a Complaint in Divorce against Petitioner in Cumberland County, Pennsylvania. 6. Concurrently with the filing of this Petition, Petitioner is filing a Complaint for Custody of Aaron Haslam, Carly Haslam and Annie Haslam. 7. The marital home is owned by the parties as tenants by the entireties. 8. The children have resided exclusively at the marital home since 1988. 9. Unless Petitioner and the parties' children are permitted exclusive possession of the marital home, the mental and emotional health and welfare of Petitioner and the children will be adversely affected and will result in irreparable harm to the children. 10. Petitioner has always been an equal caregiver with Respondent of the parties' children up until about 1997. 11. Since 1997, Petitioner has been the primary caregiver and nurturer of the parties' children. 12. An award of exclusive possession of the marital home will avoid uprooting the parties' children from the marital home and will end the tension, stress and conflict that exists because of Respondent's behavior while residing at the marital home. 13. Respondent has engaged in and is engaging in a course of conduct that has made and makes the conditions under which Petitioner and the parties' children are living intolerable, burdensome and unhealthy for the children and Petitioner. Illustrations of such conduct are the following: a. Respondent neglects her parental duties and obligations and frequently ignores Petitioner and the children. b. Respondent drinks alcohol regularly to excess and becomes drunk in the presence of the children. -2- c. Respondent stays away from the marital home overnight without forewarning Petitioner or the children and does not let Petitioner or the children know where she can be reached. d. The living conditions created by Respondent result in negative emotional effects of Petitioner and the children. e. During the marriage, Respondent has engaged and is engaging in open and flagrant marital misconduct, thereby subjecting Petitioner and children to an atmosphere of tension, stress and conflict within the marital home. 14. Respondent, despite many requests from Petitioner and the children, has failed and refused, and continues to fail and refuse to take any meaningful steps to acknowledge her problems and to overcome them. 15. Petitioner, directly and through counsel, has requested Respondent to voluntarily agree to vacate the marital home so that Petitioner and the children can have exclusive possession of it. Respondent has refused all such requests. 16. Section 3502(c) of the Divorce Code states "It]he court may award, during the pendency of the action or otherwise, to one or both of the parties the right to reside in the marital residence." 23 Pa.C.S. § 3502(c). 17. Section 3323(0 of the Divorce Code states: In all matrimonial causes, the court shall have full equity power and jurisdiction and may issue injunctions or other orders which are necessary to protect the interests of the parties or to effectuate the purposes of this part, and may grant such other relief or remedy as equity and justice require against either party or against any third person over whom the court has jurisdiction and who is involved in or concerned with the disposition of the cause. 23 Pa.C.S. § 3323(0. -3- WHEREFORE, Petitioner Michael F. Haslam respectfully requests this Honorable Court grant him and the parties' children interim exclusive possession of the marital home until the conclusion of the divorce proceedings. Respectfully Submitted, MCNEES WALLACE & NURICK, LLC Pamela L. Purdy c/ ID No. 85783 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Petitioner Michael F. Haslam -4- VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. {}4904, relating to unsworn falsification to authorities. Dated: Michael F. Haslam -- CERTIFICATE OF SERVICI' The undersigned hereby certifies that on the 11th day of July, 2002, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Samuel L. Andes, Esq. P. O. Box 168 Lemoyne, PA 17043 ~amela L. Purdy Of Counsel for Defendant Michael F. Haslam PATRICIA ANN HASLAM, Plaintiff/Respondem VS. MICHAEL F. HASLAM, IN THE COURT OF cOMMON PLEAS OF CUMBERLAND coUNTY, PENNSYLVANIA 02-2426 CIVIL CIVIL ACTION - LAW Defendant/Petitioner : ~ INTERIM EXCLUSIVE POSSESSION ORDER AND NOW, this / ?~' day of July, 2002, a rule is issued on the plaintiff/respondent to show cause why the relief requested in the within petition ought not be granted. This role returnable fifteen (15) days after service. BY THE COURT, PATRICIA ANN HASLAM, Plaintiff VS. MICHAEL F. HASLAM, Defendant NOTICE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 02-2426 CIVIL TERM IN DIVORCE TO DEFENDANT NAMED HEREIN: YOU ARE HEREBY NOTIFIED TO RESPOND TO THE ENCLOSED ANSWER AND NEW MATTER COUNTERCLAIM WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 PATRICIA ANN HASLAM, Plaintiff VS. MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2426 CIVIL TERM IN DIVORCE PLAINTIFF'S ANSWER TO DEFENDANT'S PETITION FOR SPECIAL RELIEF AND NOW comes the above-named Plaintiff by her attorney, Samuel L. Andes, and makes the following Answer, with New Matter, to Defendant's Petition for Special Relief: 1 through 5. Admitted with the clarification that the parties' three minor children reside in the custody of both Plaintiff and Defendant at 42 Wheatfield Drive in Carlisle, Pennsylvania. 6. Admitted. 7. Admitted. 8. Admitted. 9. Denied. Mrs. Haslam has been the primary care provider for the children throughout their lives and is more involved with the children, and better able to provide for their needs, than is the Defendant. The Defendant's conduct is what has caused emotional and other problems for the children and all members of the family and Mrs. Haslam believes that awarding Defendant exclusive possession of the residence will create or aggravate problems for the children as well as for Mrs. Haslam herself. 10. Denied. Mrs. Haslam has always been the primary care provider. 11. Denied. Mrs. Haslam has been the primary care giver and nurturer of the children since their birth. She is the one who has worked on a limited part-time basis so she could be available to care for the children and she has, in fact, been the primary parent for the children throughout their lives. 12. Denied. Awarding Defendant exclusive possession of the residence will disrupt and uproot the children because Mrs. Haslam believes the children will reside with her regardless of whom is awarded exclusive possession of the residence. The averments set out in Plaintiff's New Matter are incorporated herein by reference. 13. Denied. Plaintiff is not guilty of any conduct or misconduct which makes the condition of the children, or the conditions under which they live, intolerable, burdensome, or unhealthy or which adversely affect the children or Defendant. By way of further answer, Plaintiff states as follows: a. Plaintiff does not neglect her parental duties and obligations and provides good, competent, and thorough care for the children. b. Plaintiff does not regularly drink alcohol to excess or become intoxicated in the presence of the children. c. Plaintiff does not stay away from the marital home overnight without notifying the children or Defendant where she can be reached. d. Plaintiff does not create living conditions which have negative effects upon the children. To the contrary, Defendant has created an unhappy and unhealthy situation which adversely affects all of the members of the family. e. Plaintiff does not engage in open and flagrant marital misconduct and does not subject the children to an atmosphere of tension, stress, or conflict within the marital home. 14. Denied. Plaintiff denies that she has problems and needs to take steps to overcome them. Plaintiff incorporates herein, by reference, the averments set out in her New Matter. 1 5. Plaintiff admits that Defendant has requested that she vacate the marital home and allow him to have primary physical custody of the children and that she has refused such request. Plaintiff denies that the requests are realistic and denies that it would be in the children's best interest for her to remove herself from the house and allow Defendant to have primary custody of the children. 16. No answer required because these merely state conclusions of law. 17. No answer required because these merely state conclusions of law. WHEREFORE, Plaintiff prays this court to dismiss Plaintiff's petition and, if the court needs to award exclusive possession of the residence to either party, award her exclusive possession in accordance with her New Matter herein. NEW MATTER IN THE FORM OF A CROSS PETITION FOR EXCLUSIVE POSSESSION AND NOW comes the above-named Plaintiff and sets forth her own request for exclusive possession of the marital residence, based upon the following: The averments set forth in the foregoing Answer are incorporated herein by 18. reference. 19. Throughout the lives the parties' children, Plaintiff has been the primary care provider for them. Plaintiff has been the one who has not worked on a full-time basis outside the home and who has arranged her work and other schedules so that she is available to be with and care for the children. 20. Only since the martial problems between the parties has arisen has Defendant shown any real continuing and active involvement with the children. 21. Defendant has become secretive and excessively controlling in regard to his relationship with Plaintiff and the children. For example: A. Defendant has taken funds given to the parties' children by their grandfather and kept the existence, location, and investment activity of those funds secret from Plaintiff and the children. B. Defendant refused to cooperate in the enrollment of the parties' second child at Trinity High School after the child expressed a desire to attend that school. C. Defendant has unreasonably exercised complete control over the finances of the family and, in doing so, has deprived Plaintiff and the children of funds needed for various matters. D. Defendant has become withdrawn, uncommunicative, and difficult to deal with and has demonstrated this attitude toward both Plaintiff and the children. 22. Plaintiff believes that the children have become subjective to an unreasonable level of tension and anxiety in the family home because of the conduct of Defendant. 23. Plaintiff believes that the best interest of the children require that they remain in her primary physical custody if Plaintiff and Defendant separate. 24. Plaintiff believes that it is in the best interest of the children that she be awarded exclusive possession of the marital residence and that Defendant be excluded from the residence so that she and the children may reside there free from the tension and anxiety caused by Defendant and his conduct. WHEREFORE, Plaintiff prays this court to deny Defendant's petition for exclusive possession and to award her exclusive possession of the marital residence. Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 VERIFIC.___~ATION I verify that the statements made in this Answer are true and correct. I understand that any false statements in this Answer are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities), Patri~,a-A-nn ~l-a'sl am CERTIFICATE OF SERVICE I hereby certify that on 7 August 2002, I served a copy of the foregoing document upon counsel for Defendant by U.S. Mail, postage prepaid, addressed as follows: Pamela L. Purdy, Esquire 100 Pine Street P.O. Box 1166 Harrisburg, PA 17101 A-my M.l~larki'ns ' Secretary for: Samuel L. Andes Attorney for Plaintiff PATRICIA ANN HASLAM, Plaintiff/Petitioner VS. MICHAEL F. HASLAM, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE ; : NO. 2002-2426 CIVIL TERM IN DIVORCE DR~ 32030 Pacses~ 129104812 ORDER OF COURT AND NOW, this 3~d day of September, 2002, upon consideration of the attached Petition for Alimony Pcudente Lite and/or coun~l fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shadday on October 21f 2002 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rale 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Moil copies on Petitioner 9-3-02 to: < Respondent Samuel Andes, Esquire Pamela Purdy, Esquire ~~ Date of Order: September 3, 2002 MAY ATTEND ~ YOU HAVE THE RIGHT TO A LAWYER, WHO CONFERENCE 3KND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 PATRICIA ANN HASLAM, Plaintiff VS, MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2426 CIVIL TERM IN DIVORCE MOTION FOR HEARING FOR APL AND NOW comes the above-named Plaintiff by her attorney Samuel L. Andes, and moves the court for a hearing on her request for Alimony Pendente Lite, as set out in Count IV of her Divorce Complaint, a copy of which is attached hereto. 22 August 2002 Attorney for Plaintiff Supreme Court ID # 17225 525 North 1 2th Street Lemoyne, Pa 17043 (717) 761-5361 PATRICIA ANN HASLAM, Plaintiff VS, MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 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 foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 PATRICIA ANN HASLAM, Plaintiff VS, MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. PATRICIA ANN HASLAM, Plaintiff V$, MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, PATRICIA ANN HASLAM, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is PATRICIA ANN HASLAM, an adult individual who currently resides at 42 Wheatfield Drive in Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is MICHAEL F. HASLAM, an adult individual who currently resides at 42 Wheatfield Drive in Carlisle, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 27 October 1979 in Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I -- IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT II -- EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as martial property. COUNT III -- ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 1 1. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of the Plaintiff and pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV -- ALIMONY PENDENTE LITE 1 3. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT V -- COUNSEL FEES AND EXPENSES Plaintiff is without sufficient funds to retain counsel to represent her in this 15. matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigati6n. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in this litigation of this action. 'I'RUF. COPY FROM RECORD m {,~.,~irno~y whereof, I here unto set my haoa ~xxJ t,~e r,e~l 0~ sa{d Court at Carlisle. Pa. Attorney for Plaintiff Supr.eme Court ID # 17225 525 North 1 2th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). PATRICIA ANN HASLAM In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION PATRICIA A. HASLAM Plaintiff VS. MICHAEL F. HASLAM Defendant ) Docket iNumber ) ) PACSES Case Number ) ) Other State ID Number 02-2426 CIVIL 129104812 /D32030 ORDER AND NOW, to wit on this 5TH DAY OF DECEMBER, 2002 IT IS HEREBY ORDERED that the © Complaint for Support or © Petition to Modify or (~) Other ALIMONY PENDENTE LITE filed on SEPTEMBER 3 ,, 2002 in the above captioned matter is dismissed without prejudice due to: A SPOUSAL SUPPORT ORDER BEING ENTERED UNDER DOCKET NO. 756 S 2002 AND PACSES CID#539104798. O The Complaint or Petition may be reinstated upon written application of the plaimiff petitioner. BY THE COURT: Kevin A. ,- JUDGE Service Type M Form OE-506 Worker ID 210 0 5 PATRICIA ANN HASLAM, Plaintiff VS. MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2426 CIVIL TERM IN DIVORCE PETITION FOR EMERGENCY RELIEF AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes, and petitions the Court for emergency relief in this matter, based upon the following: 1. The Petitioner herein is the Plaintiff. The Respondent is the Defendant. 2. The parties are still husband and wife and are the parents of three children, Aaron M. Haslam, born 19 November 1984 and currently a senior in high school, Carly A. Haslam, born 4 August 1987, and Annie P. Haslam, born 22 January 1990. Currently the oldest and youngest child reside with Plaintiff and the middle child resides with the Defendant. 3. The parties separated in August of 2002 when Plaintiff moved out of the marital residence at 42 Wheatfield Drive in Carlisle, Pennsylvania. Defendant has remained in possession of the residence since that time. 4. Over the past week or ten days, Defendant, without Plaintiff's prior knowledge or consent, has removed a large quantity of furnishings, clothing, and other items of tangible personal property from the marital residence and placed it on the driveway and front yard of the Plaintiff's residence. He has continued this conduct despite Plaintiff's repeated requests that he cease or that he at least make arrangements with her in advance for the proper division and delivery of the items. 5. Among the items which the Defendant has dumped at the Plaintiff's home, without advance warning, are possessions of the parties' children, particularly the youngest child. 6. Many of the items which the Defendant has dumped at the Plaintiff's home have been damaged because he has delivered them during inclement weather. 7. Defendant's conduct, if continued, will do serious and irreparable harm to items of personal property which rightfully belong to Plaintiff or to the children. 8. Defendant has given no logical or reasonable explanation for his conduct. There is no reason why the items which Defendant has dumped at Plaintiff's home need to be removed. These items have remained in the marital residence since the parties' separated approximately seven months ago and there is more than adequate room in the residence to store these items. WHEREFORE, Plaintiff prays this Court to enter an order prohibiting Defendant from delivering any more items of personal property to Plaintiff's home without Plaintiff's prior consent and to order and direct Defendant to allow Plaintiff to come to the marital residence to inspect the items there so the parties can properly agree upon a division of the asset or, if they cannot agree, arrange to have the assets listed and appraised for distribution later. Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 2 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: P~'I~RICIA ANN 'FlY'LAM ' ' CERTIFICATE OF SERVICF I hereby certify that on '~i ;~5/ 2003, I served a copy of the foregoing document upon counsel for Defendant by U.S. Mail, postage prepaid, addressed as follows: Pamela L. Purdy, Esquire P.O. Box 1166 Harrisburg, PA 17108-1166 Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 4 PATRICIA ANN HASLAM, Plaintiff VS, MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2426 CIVIL TERM IN DIVORCE ORDER OF COURT AND NOW this ,,~/~-~ day of :~.~'t...~..~._~ , 2003, upon consideration of Plaintiff's Petition for Emergency Relief, a hearing is hereby scheduled, to be held before the undersigned, commencing at /0; ~ o'clock ~_~L.m., in Court Room No. ~f/ of the Cumberland County Court House, Carlisle, Pennsylvania, on _. ~'~'.(~_..~,L~O~ , the ~-t~ day of ~-~/~)~ , 2003. Until further order of this Court, Defendant shall not remove from the marital residence any further items of personal property belonging to any of the children of the parties or any items of property which are owned by Plaintiff and Defendant without Plaintiff's consent. BY THE COURT, DISTRIBUTION: ~/ Samuel L. Andes, Attorney for Plaintiff, 525 N. 12th Street, Lemoyne, PA 17043 Pamela L. Purdy, Attorney for Defendant, P.O. Box 1166, Harrisburg, PA 17108-1166 9B :IIH¥ PATRICIA ANN HASLAM, Plaintiff/Respondent VS. MICHAEL F. HASLAM, Defendant/Petitioner :. IN THE COURT OF COMMON PLE CUMBERLAND COUNTY, PENNS' : : 02-2426 CIVIL : : CIVIL ACTION - LAg/ IN RE: PETITION FOR SPECIAL RELIEF ORDER AND NOW, this day of April, 2002, on request of counsel continued generally to give the parties an opportunity to submit a proposed or. ~/Samuel Andes, Esquire For the Plaintiff /~amela Purdy, Esquire For the Defendant :rim BY THE COURT, ~A.~I-t~ss, J. q -10 AS OF (LVANIA hearing herein is [er. PATRICIA ANN HASLAM, Plaintiff VS. MICHAEL F. HASLAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2426 CIVIL TERM IN DIVORCE ORDER OF COURT AND NOW this Z :7-~ day of ~, ,2003, upon the agreement of the parties, as reported to the Court by their attorneys, we hereby cancel the hearing scheduled on the Plaintiff's Petition for Emergency Relief. Until further order of this Court, Defendant shall not remove from the marital residence any further items of personal property belonging to any of the children of the parties or any items of personal property which are owned by Plaintiff and Defendant without Plaintiff's consent. BY THE COURT, Distributi~5~: /~a,~l L. Andes, Attorney for Plaintiff, 525 N. 12th Street, Lemoyne, PA 17043 mela L. Purdy, Attorney for Defendant, P.O. Box 1166, Harrisburg, PA 17108-1166 '~N~A"IASNNBcl