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HomeMy WebLinkAbout06-5701RUTHANN K. DREWETT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO. BRAD A. DREWETT, Defendant. : 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 counseling. A list of marriage counselors is available in the Office of the Prothonotary, at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania . IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' 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 OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 JAIME D. WASSMER, ESQUIRE Robinson & Geraldo Sup. Ct. I.D. No. 200705 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 - Phone (717) 232-5098 - Fax jwassmer@robinson-geraldo.com RUTHANN K. DREWETT, Plaintiff, V. BRAD A. DREWETT, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. d? ?'7al 1.;. to t l : CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE COUNTI 1. Plaintiff is Ruthann Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 2. Defendant is Brad A. Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident 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 November 25, 1999 in Key West, Florida. 5. There have been no prior actions of divorce or for annulment between the Parties. 6. The marriage is irretrievably broken. 7. Neither Party is a member of the Armed Forces of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301(c) of the Divorce Code. COUNT II--EQUITABLE DISTRIBUTION 9. The Plaintiff incorporates by reference Paragraphs 1 through 8 of the Complaint for Divorce as fully set forth herein. 10. During the marriage, Plaintiff and Defendant have acquired various items of marital property, which are subject to equitable distribution under Section 3502 of the Pennsylvania Divorce Code of 1980, as will be fully set forth in the Plaintiffs Inventory and Appraisement to be filed pursuant to the Pennsylvania Rules of Civil Procedure. 11. Plaintiff and Defendant have been unable to agree as to an equitable division of marital property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. COUNT III--EXCLUSIVE POSSESSION OF MARITAL RESIDENCE 12. The Plaintiff incorporates by reference Paragraphs 1 through 11 of the Complaint for Divorce as fully set forth herein. 13. Plaintiff owned the marital residence prior to the parties' marriage. 14. Defendant creates a hostile environment in the marital residence and has been destructive to the marital property contained inside the home. 15. Defendant's presence in the marital residence has been disruptive to the Plaintiff and Plaintiff fears residing at the same residence as Defendant. 16. Plaintiff has been threaten by the Defendant and prays this honorable Court expels him from the marital residence. WHEREFORE, Plaintiff prays that your Honorable Court grant an Order for exclusive possession of the marital residence to Plaintiff. COUNT IV-COUNSEL FEES 17. The Plaintiff incorporates by reference paragraphs 1 through 16 of this Answer and Counterclaim as fully set forth herein. 18. Plaintiff has employed Gerald S. Robinson, Esquire, to represent her in this matrimonial cause. 19. Plaintiff is unable to pay her counsel fees, costs and expenses as she is currently unemployed due to her disability and Defendant is more than able to pay them. 20. Defendant is employed and has the ability to pay Plaintiff's counsel fees, costs and expenses. 21. Reserving the right to apply to the Court for temporary counsel fees, costs and expenses prior to final hearing, Plaintiff requests that, after final hearing, the Court order Defendant to pay Plaintiff s reasonable counsel fees, costs and expenses. WHEREFORE, Plaintiff respectfully requests that, pursuant to §§ 3104(a)(1), 3323(b) and 3702 of the Divorce Code, the Court enter an order directing Defendant to pay Plaintiff s reasonable counsel fees, costs and expenses. Respectfully submitted, ROBINSON & GERALDO 0? B Gam' Date: • l y• J ' Wassmer, Esquire Attorney for Plaintiff VERIFICATION I verify that the statements made in this Divorce Complaint\ are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. MM Ruthann Drewett W V /_7 L ' 43 Aq. © Q io ?d c? t S s'i RUTHANN K. DREWETT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : NO. 06-5701 BRAD A. DREWETT, Defendant. : 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 counseling. A list of marriage counselors is available in the Office of the Prothonotary, at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' 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 OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service Cumberland County Court Administrator 41h Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 JAIME D. WASSMER, ESQUIRE Robinson & Geraldo Sup. Ct. I.D. No. 200705 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 - Phone (717) 232-5098 - Fax jwassmer@robinson-geraldo.com RUTHANN K. DREWETT, Plaintiff, V. BRAD A. DREWETT, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5701 CIVIL ACTION - LAW IN DIVORCE AMENDED COMPLAINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE COUNT I 1. Plaintiff is Ruthann Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 2. Defendant is Brad A. Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident 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 November 25, 1999 in Key West, Florida. 5. There have been no prior actions of divorce or for annulment between the Parties. 6. The marriage is irretrievably broken. Neither Party is a member of the Armed Forces of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301(c) of the Divorce Code. COUNT II--EQUITABLE DISTRIBUTION 9. The Plaintiff incorporates by reference Paragraphs 1 through 8 of the Complaint for Divorce as fully set forth herein. 10. During the marriage, Plaintiff and Defendant have acquired various items of marital property, which are subject to equitable distribution under Section 3502 of the Pennsylvania Divorce Code of 1980, as will be fully set forth in the Plaintiffs Inventory and Appraisement to be filed pursuant to the Pennsylvania Rules of Civil Procedure. 11. Plaintiff and Defendant have been unable to agree as to an equitable division of marital property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. COUNT III--EXCLUSIVE POSSESSION OF MARITAL RESIDENCE 12. The Plaintiff incorporates by reference Paragraphs 1 through 11 of the Complaint for Divorce as fully set forth herein. 13. Plaintiff owned the marital residence prior to the parties' marriage. 14. Defendant creates a hostile environment in the marital residence and has been destructive to the marital property contained inside the home. 15. Defendant's presence in the marital residence has been disruptive to the Plaintiff and Plaintiff fears residing at the same residence as Defendant. 16. Plaintiff has been threaten by the Defendant and prays this honorable Court expels him from the marital residence. WHEREFORE, Plaintiff prays that your Honorable Court grant an Order for exclusive possession of the marital residence to Plaintiff. COUNT IV-COUNSEL FEES 17. The Plaintiff incorporates by reference paragraphs 1 through 16 of this Answer and Counterclaim as fully set forth herein. 18. Plaintiff has employed Gerald S. Robinson, Esquire, to represent her in this matrimonial cause. 19. Plaintiff is unable to pay her counsel fees, costs and expenses as she is currently unemployed due to her disability and Defendant is more than able to pay them. 20. Defendant is employed and has the ability to pay Plaintiff's counsel fees, costs and expenses. 21. Reserving the right to apply to the Court for temporary counsel fees, costs and expenses prior to final hearing, Plaintiff requests that, after final hearing, the Court order Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. WHEREFORE, Plaintiff respectfully requests that, pursuant to §§ 3104(a)(1), 3323(b) and 3702 of the Divorce Code, the Court enter an order directing Defendant to pay Plaintiff's reasonable counsel fees, costs and expenses. COUNT V - ALIMONY/ALIMONY PENDENTE LITE 22. Plaintiff incorporates by reference paragraphs 1 through 21 of the Complaint for Divorce as fully set forth herein. 23. Plaintiff is unable to sustain herself during the course of litigation. 24. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 25. Plaintiff requests the Court to enter an award of spousal support and/or alimony pendente lite until the final hearing and thereupon to enter an order of alimony in her favor pursuant to §§ 3701(a) and 3702 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests the Court to enter an award of spousal support and/or alimony pendente lite until the final hearing and thereupon to enter an order of alimony in her favor pursuant to §§ 3701(a) and 3702 of the Divorce Code. Respectfully submitted, ROBINSON & GERALDO Date: t DlQ l Ub By: J i D. Wassmer, Esquire Attorney for Plaintiff . # VERIFICATION I verify that the statements made in this Amended Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Ruthann Drewett 1 16 C? +a '? J JAIME D. WASSMER, ESQUIRE Robinson & Geraldo Sup. Ct. I.D. No. 200705 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 - Phone (717) 232-5098 - Fax jwassmer@robinson-geraldo.com RUTHANN K. DREWETT, Petitioner/Plaintiff, V. BRAD A. DREWETT Respondent/Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-5701 : CIVIL ACTION- DIVORCE PETITION FOR INJUNCTIVE RELIEF TO PREVENT DISSIPATION OF MARITAL ASSETS Petitioner files this Petition for Injunctive Relief, and in support thereof, avers as follows: 1. Petitioner Ruthann K. Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 2. Respondent is Brad A. Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 3. Petitioner filed a Complaint in Divorce requesting economic relief, including a count for equitable distribution. 4. Petitioner requests that an injunction be entered against the above-named parties and both shall be prohibited from: a. Selling, transferring, encumbering, concealing, assigning, removing or in any way disposing of any property, real or personal, belonging to or acquired by, either party, except: (a) as required for reasonable expenses of living; (b) for payment of reasonable attorney's fees and costs in connection with the action; (c) by written agreement of both parties; or (d) by Order of the Court. b. Incurring any further debts that would burden the credit of the other party, including but not limited to further borrowing against any credit line secured by the marital residence or unreasonably using credit cards or cash advances against credit or bank cards. C. Changing the beneficiary of any life insurance policy, pension or retirement plan, or pension or retirement investment account, except with the written consent of the other party or by Order of the Court. d. Causing the other party or the minor children to be removed from coverage under an existing insurance policy, or permitting such coverage to lapse, including medical, dental, life, automobile, and disability insurance. The parties shall maintain all insurance coverage in full force and effect. WHEREFORE, Petitioner respectfully request that this Honorable Court grant the Petition for Injunctive Relief and enjoin and restrain the parties from encumbering, dissipating, selling or otherwise alienating any and all marital assets of the parties. Respectfully submitted, ROBINSON & GERALDO Date: ) d 13"10(0 By4ttommeey tj DY-a smer, Esq. e Pet itioner VERIFICATION Plaintiff verifies that the statements made in this Petition for Injunction are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Ruthann K. Drew tt CERTIFICATE OF SERVICE I, Jaime Wassmer, Esquire, do hereby certify that on the day of 2006, I caused a true and correct copy of the Petition for Injunction to be served upon the following individual(s) by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Brad A. Drewett 129 Shady Lane Enola, PA 17025 Respectfully submitted, ROBINSON & GERALDO By: Jai a assmer, Esquire ?-- ?-a' ?? -r't ?? ? x'14_... - ---i -rt ! 3 .___ ? ? ?,? ? ?? C.?J _.? .. ?3, ....ti .?..; -yG JAIME D. WASSMER, ESQUIRE Robinson & Geraldo Sup. Ct. I.D. No. 200705 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 - Phone (717) 232-5098 - Fax jwassmer@robinson-geraldo.com RUTHANN K. DREWETT, Petitioner/Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5701 BRAD A. DREWETT Respondent/Defendant. CIVIL ACTION- DIVORCE PETITION FOR EMERGENCY RELIEF AND NOW comes the petitioner, Ruthann Drewett, by and through her undersigned counsel, Jaime D. Wassmer, Esquire and Robinson & Geraldo, and petitions this Court for emergency relief of custody as follows: 1. Petitioner Ruthann K. Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 2. Respondent is Brad A. Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 3. The parties in this matter are husband and wife, having been married on November 25, 1999. 4. Petitioner filed a Divorce Complaint which included a count for Exclusive Possession of the Marital Residence. A copy of the filed complaint is attached hereto as "Exhibit I". 5. Petitioner believes that a situation exists that requires emergency relief due to the following: a. Respondent is verbally abusive to Petitioner. b. Respondent does not allow Petitioner to enjoy full use of the marital residence in that he restricts Petitioner to her bedroom and does not allow her in areas of the home. C. Petitioner is afraid of Respondent due to his violent outbursts and destruction to marital property in the home. d. Respondent has packed up and removed various items of marital property from the home without Petitioner's knowledge or consent. e. Respondent's current employment involves computers and technology. Petitioner fears Respondent has hidden cameras in the home watching her and Petitioner has found evidence in the residence to substantiate this claim. f. The martial residence belonged to the Petitioner prior to her marriage to Respondent. 6. Petitioner believes Respondent will continue to dispose of marital property and persist on creating a hostile and burdensome living condition in the residence unless this Honorable Court evicts him from the marital residence. WHEREFORE, Petitioner requests that this court enter an Order granting Petitioner exclusive possession of the marital residence located at 129 Shady Lane, Enola, Pennsylvania. Respondent is immediately evicted from the premises and is prohibited from reentering until further determination by this Honorable Court. Respectfully Submitted, ROBINSON & GERALDO Date: Ib By. - Jai e . Wassmer, Esquire Attorney for Plaintiff ,. VERIFICATION I verify that the statements made in this Petition for Emergency Relief are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. aO &zetj Q Ruthann Drewett CERTIFICATE OF SERVICE I, Jaime Wassmer, Esquire, do hereby certify that on the 3ot? day of oG-v bev" , 2006, I caused a true and correct copy of the Petition for Emergency Relief to be served upon the following individual(s) by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Brad A. Drewett 129 Shady Lane Enola, Pennsylvania 17025 Respectfully submitted, ROBINSON & GERALDO By: Jai assmer, Esq. `?? r•a c--? v ?? -? --r : :? ? ? t..a -n ?? - __ __ _ _ -i-? f?- ? ?? i-i'7 . faJ C -.. " Defendant. : NO. 06-5701 : CIVIL ACTION-LAW IN DIVORCE PROOF OF SERVICE SIGNATURE AND AFFIDAVIT I, Jaime D. Wassmer, Esquire, certify that I am a competent adult not a party to this JAIME D. WASSMER, ESQUIRE Attorney I.D. No. 200705 Robinson & Geraldo, P.C. 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717)232-8525 Fax (717)232-5098 jwassmer@robinson-geraldo.com RUTHANN DREWETT, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. BRAD A. DREWETT, The undersigned makes the following return of service: the Amended Divorce Complaint was served upon Brad A. Drewett on October 28, 2006 at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsfication to authorities. Respectfully submitted, ROBINSON & GERALDO Dated: October 30, 2006 By: Ja0.. Wassmer Attorney for Plaintiff r ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: tecei (Please Pri Clearly) B. Date of elive -?I ? X. lo)2X v? ? Agent .delivery address different from item 1? U yes YES, enter delivery address below: ? No ???' S'hacly C.ctn.e_ e?n c4 iJ- P04 3. Se ice Type rtified Mail ? Express Mail E Registered ieturwReceipt for Merchandise ? Insured Mail ? C.O.D. 41: 2. Article Number 7?oy y94? 004 1686 9998 (Transfer from service label) PS Form 3811, March 2001 Domestic Return Receipt 102595-01-M-1424 :ry R RUTHANN K. DREWETT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-5701 CIVIL BRAD A. DREWETT, DEFENDANT CIVIL ACTION -DIVORCE ORDER OF COURT AND NOW, this Td day of November, 2006, upon consideration of the Petition for Emergency Relief filed by the Plaintiff, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendant to show cause why the relief requested should not be granted; 2. The Defendant will file an answer on or before November 9, 2006; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Plaintiff shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendant files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled. The Prothonotary is directed to forward said Answer to this Court. By the Court, . ?* J, ?AA M. L. Ebert, Jr., J. Jamie D. Wassmer, Esquire , Attorney for Plaintiff Brad Drewett Defendant bas X15 I S" :Z 1, 1,.A C- AON S, ?, ? Z RUTHANN K. DREWETT, PLAINTIFF V. BRAD A. DREWETT, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5701 CIVIL CIVIL ACTION - DIVORCE ORDER OF COURT AND NOW, this 3d day of November, 2006, upon consideration of the Petition for Injunctive Relief, IT IS HEREBY ORDERED AND DIRECTED that a hearing shall be held on Monday, January 8, 2007 at 1:30 p.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. Pending said hearing IT IS FURTHER ORDERED AND DIRECTED that the parties are enjoined from encumbering, dissipating, selling or otherwise alienating any and all marital assets of the parties. By the Court, M. L. Ebert, Jr., J. Jaime D. Wassmer, Esquire Attorney for Plaintiff Brad Drewett Defendant It - 3- C(? Cr?? ???. ,JV5- bas I s :Z '<# C- hoN S60Z Darren J. Holst, Esquire HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant, Brad A. Drewett IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RUTHANN K. DREWETT, ) Plaintiff ) V. ) BRAD A. DREWETT, ) Defendant ) NO. 06-5701 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S ANSWER AND NEW MATTER TO PLAINTIFF'S PETITION FOR EMERGENCY RELIEF AND NOW, comes Defendant, Brad A. Drewett, by and through his counsel, Howett, Kissinger, Conley & Holst, P.C., who hereby files the instant Answer and New Matter to Plaintiffs Petition for Emergency Relief and in support thereof states as follows: 1. Admitted. Hereafter, Plaintiff is referred to as "Wife." 2. Admitted. Hereafter, Defendant is referred to as "Husband." 3. Admitted. By way of further response, prior to their marriage the parties dated sporadically from as early as the mid to the late 1980s. The parties further resided together prior to their marriage, and throughout the parties' relationship, Husband has acted as Wife's caretaker because Wife suffers from ADHD and other ailments. 4. Admitted in part; denied in part. Husband admits Wife filed a divorce complaint, in which she raised a count for exclusive possession. Husband denies, however, there is any merit to Wife's request for exclusive possession, and he further denies the factual averments raised by Wife within Count III of her divorce complaint, in which she seeks exclusive possession, and strict proof thereof is demanded at hearing. The Rules of Civil Procedure do not require a defendant to file an answer to a divorce complaint as all averments are deemed denied as a matter of law. 5. Denied. Husband is unable to respond as to what Wife may believe as Husband is without information as to such facts. To the extent a response is required, it is denied. Husband denies that any situation now exists (or previously existed) requiring emergency relief, and he responds specifically to the subparagraphs of Wife's paragraph #5 as follows: (a) Denied. Husband denies ever being verbally abusive to Wife. While Husband admits the parties have argued and disagreed over time, Husband denies he has acted in any way to be "verbally abusive" to Wife, and strict proof thereof is demanded at trial. In fact, it is Wife who has lashed out at Husband over the course of their relationship. Wife historically has struggled with anger management issues, and she has seen a therapist for such issues over the last ten years. While Wife's behavior has progressively gotten better over time, there have been times during the parties' relationship where Wife has attacked Husband and caused deep scratching to Husband's face, which has drawn blood. While it has been some time since Wife has physically attacked Husband in such a fashion, Wife still struggles with anger issues, and she is quick to become argumentative with Husband and engage in verbal tirades. As such, Husband has actually tried to avoid Wife by working long hours and isolating himself to his home office when at the residence with her. 2 (b) Denied. Husband denies he has restricted Wife's use of the marital residence in any way shape or form and strict proof thereof is demanded at trial. Husband admits both parties, have, for some time, slept in separate bedrooms (as a result of Wife's snoring), and he concedes the parties are living more like roommates at this time. Nevertheless, Wife has full reign of the marital residence and, in fact, it is Husband who routinely restricts himself to his home office, which allows Wife to have use of the entire residence, due to his desire to avoid a situation where Wife can lash out at him. (c) Denied. Husband is without information as to what Wife may feel and is therefore unable to answer that part of the averment. To the extent a response is required, Husband denies Wife has any reason to be afraid of him, and he further denies engaging in "violate outbursts" and "destruction to marital property" within the home, and strict proof thereof is demanded at trial. Wife suffers from various physical and mental ailments, and it is Husband who has routinely taken care of her needs by ensuring she both attends all medical appointments (when she tells Husband of the appointments in advance) and takes her exhaustive list of medications. Throughout the parties' long term relationship, it is Wife, and not Husband, who has battled issues of anger management and uncontrolled range, and it is she who has engaged in violent outbursts towards Husband; at times in the past she has physically assaulted Husband to the point of drawing blood. However, with the aid of her therapist, Wife has been able to aggressively work on her anger management issues, which has helped to ameliorate the right in their relationship. Husband typically tries to avoid Wife at the residence, particularly given the fact that she has now filed for divorce, and he has no desire to engage Wife in confrontation as that will simply protract the litigation and increase each side's costs exponentially. Instead, 3 Husband desires to resolve all matters amicably, and he is hopeful that can occur. He certainly has not destroyed any property within the house as that affects the value of marital property to be divided between the parties upon divorce. (d) Denied. Husband denies packing up and removing items of marital property from the residence without Wife's knowledge or consent and strict proof thereof is demanded at trial. Regrettably, presumably as a result of the numerous medications Wife takes, Husband has noticed that Wife can be forgetful and disorganized at times. In fact, Wife's own sisters, as recently as one month ago, attempted to have Wife committed to a psychiatric hospital based upon perceived mental incompetence, and the sisters demanded Wife give them a power of attorney over her affairs. It is Husband who came to Wife's defense denying Wife was mentally incompetent, and he is was able to persuade the police, who were called to the house, that Wife was not a candidate for involuntary commitment. The police agreed and refused to detain Wife; nevertheless, Wife can be forgetful, and as a result of the extreme clutter around the marital residence, Wife has been known to be disorganized and lose track of items. To the extent Wife believes items of marital property may be missing, it is more likely the result of Wife's own forgetfulness or her inability to find the items given the current state of the residence. (e) Admitted in part; denied in part. Husband admits his current employment involves the need to work with computers and understand developing computer technology, including video conferencing via computer. Husband adamantly denies, however, that he has installed hidden cameras in the marital residence and strict proof thereof is therefore demanded at trial. While Wife indicates within her petition she has "evidence" of such claims, she provides no solid facts within the body of her petition to support such a claim (and to provide 4 notice to Husband), and inasmuch as Pennsylvania is a fact pleading jurisdiction, which requires a complainant plead with specificity all facts supporting all allegations, Wife's general averment in subparagraph (e) should be stricken as scandalous and lacking the specific factual basis necessary for pleading within Pennsylvania. Moreover, Wife's averment is evidence of potential delusional thinking, which greatly concerns Husband. The fact is, Husband has not installed cameras within the residence, and if Wife truly believes this fact, Husband implores Wife to seek additional treatment for such delusions. (f) Admitted in part; denied in part. Husband admits the marital residence is Wife's premarital property; therefore, upon divorce Wife is entitled to retain the residence. Notwithstanding, the fact the residence is Wife's premarital property does not support, by itself, a claim for exclusive possession during the pendency of the divorce action. While the residence belongs to Wife, it is the residence in which the parties resided throughout marriage, and Husband has a marital, equitable interest to continue to reside in the residence until the divorce is concluded. As Wife is presently on disability, the parties simply do not have the financial wherewithal to support pending divorce litigation and have the parties maintain separate residences. There is no reason the parties cannot co-exist peacefully within the residence during the pendency of the divorce action. As Husband desires an expeditious and amicable resolution of all issues, Husband sees no reason why this matter cannot be promptly resolved, which will result in Husband securing his own residence and vacating the premises as soon as possible. At this time, however, it is simply impossible for him to secure and pay for alternate accommodations, continue to pay substantial marital debt and provide appropriate support to Wife. Requiring Husband to do all of this will destroy the parties financially, which is counterintuitive to the expressly stated goals of the Divorce Code, which seeks to preserve the 5 family, mitigate harm to the spouses and effectuate economic justice. See 23 Pa.C.S.A. § 3102(a) (2001). 6. Denied. As Husband is without information as to what Wife believes, he is unable to respond affirmatively to the averment. However, to the extent a response is required, it is denied. Husband denies he has engaged in, or will engage in the future, a scheme to dispose marital property and create a hostile and burdensome living condition within the residence. It is Husband who has attempted to maintain civility by attempting to co-exist within the residence, living essentially as roommates. There is simply no justification for this Court to grant Wife exclusive possession of the residence at this time, as the parties can reside within the residence during the pendency of the divorce action. Husband has already acknowledged he will agree to the entry of an order preventing either party from dissipating, alienating or secreting marital property, which should assuage Wife's concerns of dissipation. WHEREFORE, Defendant respectfully requests this Honorable Court enter an order denying Plaintiff's request for exclusive possession of the marital residence. NEW MATTER - REQUEST FOR ATTORNEYS' FEES 7. The prior paragraphs of this Answer are incorporated herein by reference thereto as if set forth at length. 8. Wife lacks any justification to seek exclusive possession of the residence at this time or other than her argument that the house is her pre-marital property, which, by itself is sufficient. 6 9. Notwithstanding, Wife has elected to pursue, seemingly as litigation strategy, a claim for exclusive possession, and in support thereof, she has crafted an "emergency petition" in which she makes baseless allegations of inappropriate conduct on the part of Husband. 10. Wife has the burden of proving these allegations by a preponderance of the evidence, which Husband insists Wife cannot do. 11. In fact, Wife's claims that Husband has been abusive, has destroyed property and surreptitiously recorded her would, outside the context of litigation, constitute libelous statements. 12. Pursuant to Section 2503(7) of the Judicial Code, the Court can award a party attorneys' fees where the conduct of the other party is vexatious, obstreperous and obdurate. 13. Wife's actions in fabricating such allegations against Husband, seemingly designed strategically to remove Husband from the residence contemporaneously with Wife's filing a divorce, constitutes vexatious conduct thereby entitling Husband to an award of attorneys' fees under the Judicial Code. 14. In having to respond to the instant emergency petition, Husband has incurred attorneys' fees, and he will continue to incur attorneys' fees in preparing for and attending any hearing thereon. 7 WHEREFORE, Defendant, Brad A. Drewett, respectfully requests this Honorable Court enter an award pursuant to Section 2503(7) of the Judicial Code awarding him attorneys' fees and costs incurred as part of this action. Respectfully submitted, Date: L 6 Darren J. H st, Esquire HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street / P. 0. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant, Brad A. Drewett 8 VERIFICATION I, Brad A. Drewett, hereby swear and affirm that the facts contained in the foregoing Defendant's Answer and NPw MattPr_tO Plaintiff's Petition for are Emergency Relief true and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: 11/16/06 Brad A. Drewett IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RUTHANN K. DREWETT, Plaintiff ) NO. 06-5701 CIVIL TERM V. ) BRAD A. DREWETT, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE CERTIFICATE OF SERVICE I, Darren J. Holst, Esquire, counsel for Brad A. Drewett, Defendant in the above- captioned action, hereby certify that a true and correct copy of the foregoing Answer to Plaintiff s Petition for Emergency Relief was served upon Jaime D. Wassmer, Esquire, counsel for Plaintiff, Ruthann K. Drewett, via hand delivery and by depositing same in the United States mail, first class, on November 16, 2006, addressed as follows: Jaime D. Wassmer, Esquire ROBINSON & GERALDO 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110-5320 Date: // //(/!, co l Darren J. 1st, Esquire HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: 717-234-2616 Counsel for Defendant, Brad A. Drewett C? C-1' • Wig:: _; ::: ? JAIME D. WASSMER, ESQUIRE Attorney I.D. No. 200705 Robinson & Geraldo, P.C. 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717)232-8525 Fax (717)232-5098 jwassmer@robinson-geraldo.com RUTHANN DREWETT, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5701 BRAD A. DREWETT, Defendant. CIVIL ACTION- DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Petition For Injunction Relief was served upon Brad Drewett on November 9, 2006 at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Jaime D. Wassmer, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsfication to authorities. Respectfully submitted, ROBINSON & GERALDO Dated: November 14, 2006 B Y: Jai , . Wassmer Attorney for Plaintiff w ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this cans to the back of the mailpiece, or on the front if space permits. 1. Art le Addressed to: shady Lance .O ro t a i ell I o?S' A. by Print C) B. Date of Delivery G' C. Sklre X 0 Agent D. Is delivery address different from item 1? 13 Yes If YES, enter delivery adSyeS` Se ol`Dv .? O No 3. Servjce Type / .1, 1- ....- ` y [ Certified Mail ? V egistered tu!R Return eceipt for Merchandise 0 Insured Mail 0 C.O.D. 2. Article Number (transfer from service label 7 a a 1 1940 0004 1687 0352 PS Form 3811, March 2001 Domestic Return Receipt 102595-01-M-1424 ,3 tv.: JAIME D. WASSMER, ESQUIRE Attorney I.D. No. 200705 Robinson & Geraldo, P.C. 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717)232-8525 Fax (717)232-5098 jwassmer@robinson-geraldo.com RUTHANN DREWETT, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5701 BRAD A. DREWETT, Defendant. CIVIL ACTION- DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Petition For Emergency Relief was served upon Brad Drewett on November 9, 2006 at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT action. I, Jaime D. Wassmer, Esquire, certify that I am a competent adult not a party to this I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsfication to authorities. Respectfully submitted, ROBINSON & GERALDO Dated: November 14, 2006 By. C11- - --- Jai D. assmer Attorney for Plaintiff • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. Print your name and address on the reverse so that we can return the card to you. Attach this card to the back of the mailpioM_ or on the front if space permits. - 1 Article Addr"?D ice! Shady Lane- ncyta P? 1'70 s (Pleas pdnr clearly) I B. Date of Del Ctat fJ C. Signature ? Agent ? Addmeme 1s delivery address different from item flg If YES, ejWOeIWm adi;tpE bell • ?o .?LLI 3. Service Type 0 Wif ied Mail , O Mail Registered Receipt for Mercharxsee E To' ? In" Mail 0?6.oa 2. Article Number 7001 1940 00134 aii (Transfer from service labeil P Form 3811, March 2001 Domestic PA*um ROWOU 10259"1•M-1424 ?! C:a r - . r RUTHANN K. DREWETT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5701 CIVIL BRAD A. DREWETT, : DEFENDANT CIVIL ACTION - DIVORCE ORDER OF COURT AND NOW, this 22"d day of November, 2006, upon consideration of the Petition for Emergency Relief Requesting Exclusive Possession of the Marital Residence filed by the Plaintiff and the Defendant's Answer thereto, IT IS ORDERED AND DIRECTED that a hearing will be held on this issue on January 8, 2007 at 1:30 p.m., the same time as the hearing on the Petition for Injunctive Relief. By the Court, /aime D. Wassmer, Esquire Attorney for Plaintiff .46arren J. Holst, Esquire Attorney for Defendant bas J ?* I M. L. Ebert, Jr., 1 ?? ,.? _ ,, v,?P?.^? p . e i .. ?; ?.? .' ?? .i `, n. ?;?`:I ;LAG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RUTHANN K. DREWETT, ) Plaintiff ) V. ) BRAD A. DREWETT, ) Defendant ) NO. 06-5701 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S ANSWER TO PLAINTIFF'S PETITION FOR INJUNCTIVE RELIEF TO PREVENT DISSIPATION OF MARITAL ASSETS AND NOW, comes Defendant, Brad A. Drewett, by and through his counsel, Howett, Kissinger, Conley & Holst, P.C., who hereby files the following Answer to Plaintiff's Petition for Injunctive Relief to Prevent Dissipation of Marital Assets and in support thereof responds as follows: 1. Admitted. Hereafter Plaintiff is referred to as "Wife." 2. Admitted. Hereafter Defendant is referred to as "Husband." Admitted. By way of further response, Rule 1920.14(a) does not require that an Answer be filed to a Complaint in Divorce as all claims raised within a Complaint are deemed denied unless specifically admitted by an Answer thereto. Husband has not filed an Answer to the Divorce Complaint in light of said Rule; thus, the averments are deemed denied. 4. Admitted. Husband concurs with Wife's request that an Order be entered specifically precluding both parties from: A. Selling, transferring, encumbering, concealing, signing, removing or in any way disposing of any marital property, real or personal, absent agreement of the parties or Order of Court; B. Incurring any further joint debts; C. Changing the beneficiary designations of any life insurance policies, pension or retirement plans, prior to the entry of a Divorce Decree, absent agreement of the parties or Order of Court; and D. Continue maintenance of all health insurance policies for the benefit of both parties. WHEREFORE, Respondent specifically concurs with the relief requested by the Petitioner and, therefore, requests this Honorable Court enter an Order enjoining both parties from encumbering, dissipating, selling or otherwise alienating marital assets. Respectfully submitted, Date: /D ` - / Darren J. olst, Esquire HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant, Brad A. Drewett VERIFICATION I, Brad A. Drewett, hereby swear and affirm that the facts contained in the foregoing Defendant's Answer to Plaintiff's Petition for Injunctive RPJJPf to Prevent are Dissipation of Marital Assets true and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: December 29, 2006 77?:=2? Brad A. Drewett IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RUTHANN K. DREWETT, ) Plaintiff ) NO. 06-5701 CIVIL TERM V. ) BRAD A. DREWETT, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE CERTIFICATE OF SERVICE I, Darren J. Holst, Esquire, counsel for Brad A. Drewett, Defendant in the above- captioned action, hereby certify that a true and correct copy of the foregoing Defendant's Answer to Plaintiff's Petition for Injunctive Relief to Prevent Dissipation of Marital Assets was served upon Jaime D. Wassmer, Esquire, counsel for Plaintiff, Ruthann K. Drewett, by depositing same in the United States mail, first class, on December 29, 2006, addressed as follows: Jaime D. Wassmer, Esquire ROBINSON & GERALDO 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110-5320 Date: Darren J. olst, Esquire HOWETT, KISSINGER, CONLEY & HOLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant, Brad A. Drewett a rn ? ? - Y w ? . f{ , ? JAIME D. WASSMER, ESQUIRE Attorney I.D. No. 200705 Robinson & Geraldo, P.C. 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717)232-8525 Fax (717)232-5098 jwassmer@robinson-geraldo.com RUTHANN DREWETT, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-5701 BRAD A. DREWETT, Defendant. : CIVIL ACTION DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Tresspass Notice was served upon Darren Holst, Esquire on April 26, 2007 at 130 Walnut Street, Harrisburg, Dauphin County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Jaime D. Wassmer, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsfication to authorities. Respectfully submitted, ROBINSON & GERALDO Dated: April 30, 2007 By: Jaime6y Wassmer, Esquire Attorney for Plaintiff I ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: barren ?Ws+i ESQ ISO W al nul- S? ee?- f -}u rris burl t PA 1,1101 A. S o _ X t rt by Apod M 26 e Of D. Is ivery address item 1? Y If YES, enter delivery add 9AINI 3. Serv", e, 19?C qp,latl !( Mall me tared _ „???ilecelpt for Merchr ridk; ? Insured Mail 13-C.O.D. 4. RestricQ taiivery7OF ft Fes) 2. Article Number 7001 1940 0004 1687 0734 (> Rrrsf from service kw PS Form 3811, February 2004 Domestic Paturn Receipt 102585-02•M-1540 EXHIBIT i) RUTHANN K. DREWETT, V. Plaintiff, BRAD A. DREWETT, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5701 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE Kindly withdraw the appearance of Jaime D. Wassmer, Esquire, on behalf of the Plaintiff in the above-captioned matter. Respectfully submitted, ROBINSON & GERALDO Date: ' - l '4Jae D. Wassmer, Esquire PRAECIPE TO ENTER APPEARANCE Kindly enter the appearance of Gerald S. Robinson, Esquire, on behalf of the Plaintiff in the above-captioned matter. Respectfully submitted, Z? lob Date: j ROBINS.? & GERALDO __j'?. /' I By: ICJ - -' v G ald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525 =} _„r `S? ?-t - ?4' r^ r ?.? `? ri t,;_ - _ Ei1 1 L.- f-, _ ? •-'-- . ? -( ?e? .? v ?, ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RUTHANN K. DREWETT, Plaintiff ) NO. 06-5701 CIVIL TERM V. ) BRAD A. DREWETT, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on October 15, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: r7 7i:L? Brad A. Drewett, Defendant t.. c ? '? i l;,f v i i.3 s t ?"; i ?? . ?; 1,1? _ ... r- RUTHANN K. DREWETT, Plaintiff, V. BRAD A. DREWETT, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5701 CIVIL ACTION - LAW IN DIVORCE PETITION FOR LEAVE TO WITHDRAW AS COUNSEL The petition of Gerald S. Robinson, Esq. and the law office of Robinson and Geraldo, respectfully represents the following: 1. Plaintiff in this action is Ruthann Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. Plaintiff retained the office of Robinson & Geraldo on September 6, 2006 to represent her in a divorce action. 2. Professional considerations require termination of representation. 3. On May 25, 2007, Petitioner received notice that the firm of Robinson and Geraldo, its attorneys and staff, had been discharged by the Plaintiff. 4. Counsel for Defendant does not object to this request. WHEREFORE, undersigned counsel requests that this Court grant leave to withdraw as counsel appearance for plaintiff in this action. Respectfully submitted, ROBINSON & GERALDO Date: 61v I d') By: G ld S. Robinson, Esq. Attorney for the Plaintiff i • ti CERTIFICATE OF SERVICE 4K I, Jaime Wassmer, do hereby certify that on the Y day of M OLY , 2007,1 caused a true and correct copy of the Petition to Withdraw Appearance to be served upon the following individual(s) by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Ruthann Drewett 129 Shady Lane Enola, PA 17025 Darren Hoist, Esq. Howett, Kissinger, Conley & Hoist, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17101 Respectfully submitted, ROBINSON & GERALDO B J e Wassmer, Esquire t) C : -V 3C M C7 N -t Z7 RUTHANN K. DREWETT, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : NO. 06-5701 BRAD A. DREWETT, Defendant. : CIVIL ACTION - LAW IN DIVORCE AMENDMENT TO PETITION FOR LEAVE TO WITHDRAW AS COUNSEL The petition of Gerald S. Robinson, Esq. and the law office of Robinson and Geraldo, respectfully represents the following: 1. Plaintiff in this action is Ruthann Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. Plaintiff retained the office of Robinson & Geraldo on September 6, 2006 to represent her in a divorce action. 2. On October 3, 2006 the Honorable Judge Kevin A. Hess issued an Order directing the parties to appear before a conference officer of the Domestic Relations section on October 25, 2006. A copy of the October 3, 2006 Order is attached hereto as "Exhibit 1". This conference was later rescheduled for November 16, 2006. A copy of the rescheduling Order is attached hereto as "Exhibit 2". 3. On November 3, 2006 the Honorable Judge M.L. Ebert Jr., issued an Order upon consideration of a Petition for Injunctive Relief, that the parties would appear for a hearing on January 8, 2007. A copy of the November 3, 2006 Order and accompanying Petition for Injunctive Relief are attached hereto as "Exhibit 3". 4. On November 3, 2006 the Honorable Judge M.L. Ebert Jr., issued an Order upon consideration of a Petition for Emergency Relief filed by undersigned counsel of behalf of the Plaintiff in this case, that a Rule would be issued on Defendant to show cause why the relief requested should not be granted. A copy of the November 3, 3006 Order and accompanying Petition for Emergency Relief are attached hereto as "Exhibit 4". On November 22, 2006 the Honorable Judge M.L. Ebert Jr., issued an Order upon consideration of the above mentioned Petition for Emergency Relief, that the parties would appear for a hearing on January 8, 2007 to address both the Petition for Emergency Relief and the Petition for Injunctive Relief. A copy of the November 22, 2006 Order is attached hereto as "Exhibit 5". 6. On November 21, 2006 the Honorable Judge Kevin A. Hess issued an Order dismissing the Plaintiff s Complaint for Support with prejudice. A copy of the November 21, 2006 Order is attached hereto as "Exhibit 6". 7. Professional considerations require termination of representation. 8. On May 25, 2007, Petitioner received notice that the firm of Robinson and Geraldo, its attorneys and staff, had been discharged by the Plaintiff. 9. Counsel for Defendant does not object to this request. WHEREFORE, undersigned counsel requests that this Court grant leave to withdraw as counsel appearance for plaintiff in this action. Respectfully submitted, ROBINSON & GERALDO Date: U Z? 61 By: Geral S. Robinson, Esq. Attorney for the Plaintiff CERTIFICATE OF SERVICE 10 I, Jaime Wassmer, do hereby certify that on the o2? day of , 2007,1 caused a true and correct copy of the Petition to Withdraw Appearance to be served upon the following individual(s) by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Ruthann Drewett 129 Shady Lane Enola, PA 17025 Darren Holst, Esq. Howett, Kissinger, Conley & Holst, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17101 Respectfully submitted, ROBINSON & GERALDO By. J - e assmer, Esquire In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION RUTHANN K. DREWETT ) Docket Number 0 0 8 5 4 S 2006 Plaintiff ) vs. ) PACSES Case Number 126108655 BRAD A. DREWETT ) Defendant ) Other State ID Number ORDER OF COURT You, RUTHANN K. DREWETT 129 E SHADY LN, ENOLA, PA. 17025-2328-29 plaintiff/defendant of are ordered to appear at CUMBERLAND CO DRS O 13 NORTH HANOVER STREET, CARLISLE, PA. 17013 CC:7 3a... 3"_1 before a conference officer of the Domestic Relations Section, on z OCTOBER 25, 2006 at 9: ooAM for a conference, after w e z? conference officer may recommend that an order for support be entered. You are further required to bring to the conference: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Q F? 4 I .50 W Cn Service Type M EXHIBIT Form CM-508 Worker ID 21205 DREWETT V• DREWETT PACSES Case Number: 126108655 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. 11 paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: OCT 0 3 2006, JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. Page 2 of 2 Form CM-508 Service Type M Worker ID 21205 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION RU-MAND7 K. DREWETT ) Docket Number 00854 5 2006 Plaintiff ) VS. ) PACSES Case Number 126108655 BRAD A. DREWETT ) Defendant ) Other State ID Number ORDER OF COURT You, BRAD A. DREWETT plaintiff/defendant of 129 E SHADY LN, ENOLA, PA. 17025-2328-29 0 «, t s'? o c o C= 30 a :X o are ordered to appear at CUMBERLAND CO DRS M(Arn ?? r- j C3 13 NORTH HANOVER STREET, CARLISLE, PA. 17013 Zoo VJ O ::O'n rn ry? n n Y o?cn before a conference officer of the Domestic Relations Section, on 4o? 00 -C:2 lydl 04 OCTOBER 25, 2006 at 9: ooAM for a conference, after which the- conference officer may recommend that an order for support be entered. You are further required to bring to the conference: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Form CM-508 Service Type M Worker ID 21205 DREWETT v• DREWETT PACSES Case Number: 126108655 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: Arl 0 3 7006 JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-622s . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. Page 2 of 2 Form CM-508 Service Type M Worker I D 21205 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION RUTHANN K. DREWETT ) Docket Number 0 0 8 5 4 5 2006 Plaintiff ) VS. ) PACSES Case Number 126108655 BRAD A. DREWETT ) Defendant ) Other State ID Number ORDER OF COURT - RESCHEDULE A CONFERENCE You, RUTHANN K. DREWETT plaintiff/defendant of 129 E SHADY LN, ENOLA, PA. 17025-2328-29 are ordered to appear at CUMBERLAND CO DRS 13 NORTH HANOVER STREET, CARLISLE, PA. 17013 before a conference officer of the Domestic Relations Section, on the 16TH DAY OF NOVEMBER, 2006 at 10:3OAM for a conference, after which the conference officer may recommend that an order be entered. This date replaces the prior conference date of OCTOBER 25, 2006 You are further required to bring to the conference: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Rule 1910.11 (c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. information relating to professional licenses 7. other: Service Type M ExmBIT D Form CM-513 Worker ID 21205 DREWETT v. DREWETT PACSES Case Number: 126108655 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: OCT 2 5 2056 JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBERLAND County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. Form CM-513 Service Type M Worker ID 21205 RUTHANN K. DREWETT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5701 CIVIL BRAD A. DREWETT, : DEFENDANT CIVIL ACTION - DIVORCE ORDER OF COURT AND NOW, this 3`d day of November, 2006, upon consideration of the Petition for Injunctive Relief, IT IS HEREBY ORDERED AND DIRECTED that a hearing shall be held on Monday, January 8, 2007 at 1:30 p.m. in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. Pending said hearing IT IS FURTHER ORDERED AND DIRECTED that the parties are enjoined from encumbering, dissipating, selling or otherwise alienating any and all marital assets of the parties. By the Court, h\\ -A. M. L. Ebert, Jr., J. Jaime D. Wassmer, Esquire Attorney for Plaintiff Brad Drewett Defendant bas 11* Y FROM R RID '? t 01fy1w1Agt?t, 1 hp!re Ufft So tf* sew of W., Pa t-t EXHIBIT JAIME D. WASSMER, ESQUIRE Robinson & Geraldo Sup. Ct. I.D. No. 200705 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 - Phone (717) 232-5098 - Fax jwassmer@robinson-geraldo.com RUTHANN K. DREWETT, Petitioner/Plaintiff, V. BRAD A. DREWETT Respondent/Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5701 : CIVIL ACTION- DIVORCE PETITION FOR INJUNCTIVE RELIEF TO PREVENT DISSIPATION OF MARITAL ASSETS Petitioner files this Petition for Injunctive Relief, and in support thereof, avers as follows: 1. Petitioner Ruthann K. Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 2. Respondent is Brad A. Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 3. Petitioner filed a Complaint in Divorce requesting economic relief, including a count for equitable distribution. 4. Petitioner requests that an injunction be entered against the above-named parties and both shall be prohibited from: a. Selling, transferring, encumbering, concealing, assigning, removing or to any way disposing of any property, real or personal, belonging to or acquired by, either party, except: (a) as required for reasonable expenses of living; (b) for payment of reasonable attorney's fees and costs in connection with the action; (c) by written agreement of both parties; or (d) by Order of the Court. b. Incurring any further debts that would burden the credit of the other party, including but not limited to further borrowing against any credit lime secured by the marital residence or unreasonably using credit cards or cash advances against credit or bank cards. C. Changing the beneficiary of any life insurance policy, pension or retirement plan, or pension or retirement investment account, except with the written consent of the other party or by Order of the Court. d. Causing the other party or the minor children to be removed from coverage under an existing insurance policy, or permitting such coverage to lapse, including medical, dental, life, automobile, and disability insurance. The parties shall maintain all insurance coverage in full force and effect. WHEREFORE, Petitioner respectfully request that this Honorable Court grant the Petition for Injunctive Relief and enjoin and restrain the parties from encumbering, dissipating, selling or otherwise alienating any and all marital assets of the parties. Respectfully submitted, ROBINSON & GERALDO Date: By: Jaime D. Wassmer, Esq. Attorney for the Petitioner VERIFICATION Plaintiff verifies that the statements made in this Petition for Injunction are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Ruthann K. Drewett CERTIFICATE OF SERVICE I, Jaime Wassmer, Esquire, do hereby certify that on the day of 2006, I caused a true and correct copy of the Petition for Injunction to be served upon the following individual(s) by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Brad A. Drewett 129 Shady Lane Enola, PA 17025 Respectfully submitted, ROBINSON & GERALDO By: Jaime Wassmer, Esquire RUTHANN K. DREWETT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5701 CIVIL BRAD A. DREWETT, DEFENDANT CIVIL ACTION - DIVORCE ORDER OF COURT AND NOW, this T'° day of November, 2006, upon consideration of the Petition for Emergency Relief filed by the Plaintiff, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendant to show cause why the relief requested should not be granted; 2. The Defendant will file an answer on or before November 9, 2006; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Plaintiff shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Defendant files an answer to this Rule to Show Cause, and the answer raises disputed issues of material fact, an evidentiary hearing will then be scheduled. The Prothonotary is directed to forward said Answer to this Court. By the Court, ?AA. M. L. Ebert, Jr., (j J. Jamie D. Wassmer, Esquire Attorney for Plaintiff Brad Drewett Defendant bas TAE GOPY FROM RED ?,99" vBt w, I here unto sow i the We! d Said C=. , cam, Pa. EXHIBIT ? y s JAIME D. WASSMER, ESQUIRE Robinson & Geraldo Sup. Ct. I.D. No. 200705 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 - Phone (717) 232-5098 - Fax jwassmer@robinson-geraldo.com RUTHANN K. DREWETT, Petitioner/Plaintiff, v. BRAD A. DREWETT Respondent/Defendant. ?? 4l - ^ -r, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Ob-5701 CIVIL ACTION- DIVORCE PETITION FOR EMERGENCY RELIEF AND NOW comes the petitioner, Ruthann Drewett, by and through her undersigned counsel, Jaime D. Wassmer, Esquire and Robinson & Geraldo, and petitions this Court for emergency relief of custody as follows: I . Petitioner Ruthann K. Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 2. Respondent is Brad A. Drewett, who currently resides at 129 Shady Lane, Enola, Cumberland County, Pennsylvania. 3. The parties in this matter are husband and wile, having been _named on 1,4ovem er 25., 1999. 4. Petitioner filed a Divorce Complaint which included a count for Exclusive Possession of the Marital Residence. A copy of the filed complaint is attached hereto as "Exhibit 1 ". 5. Petitioner believes that a situation exists that requires emergency relief due to the following: a. Respondent is verbally abusive to Petitioner. b. Respondent does not allow Petitioner to enjoy full use of the marital residence in that he restricts Petitioner to her bedroom and does not allow her in areas of the home. C. Petitioner is afraid of Respondent due to his violent outbursts and destruction to marital property in the home. d. Respondent has packed up and removed various items of marital property from the home without Petitioner's knowledge or consent. e. Respondent's current employment involves computers and technology. Petitioner fears Respondent has hidden cameras in the home watching her and Petitioner has found evidence in the residence to substantiate this claim. f. The martial residence belonged to the Petitioner prior to her marriage to Respondent. 6. Petitioner believes Respondent will continue to dispose of marital property and persist on creating a hostile and burdensome living condition in the residence unless this Honorable Court evicts him from the marital residence. WHEREFORE, Petitioner requests that this court enter an Order granting Petitioner exclusive possession of the marital residence located at 129 Shady Lane, Enola, Pennsylvania. Respondent is immediately evicted from the premises and is prohibited from reentering until further determination by this Honorable Court. Respectfully Submitted, ROBINSON & GERALDO Date. By. . Jaime A. Wassmer, Esquire Attorney for Plaintiff VERIFICATION 1 verify that the statements made in this Petition for Emergency Relief are true and correct. I understand that false statements herein are made subject to the Penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Ruthann Drewett CERTIFICATE OF SERVICE I, Jaime Wassiner, Esquire, do hereby certify that on the day of 2006, I caused a true and correct copy of the Petition for Emergency Relief to be served upon the following individual(s) by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Brad A. Drewett 129 Shady Lane Enola, Pennsylvania 17025 Respectfully submitted, ROBINSON & GERALDO By. Jaime Wassmer, Esq. RUTHANN K. DREWETT, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-5701 CIVIL BRAD A. DREWETT, DEFENDANT CIVIL ACTION - DIVORCE ORDER OF COURT AND NOW, this 22"d day of November, 2006, upon consideration of the Petition for Emergency Relief Requesting Exclusive Possession of the Marital Residence filed by the Plaintiff and the Defendant's Answer thereto, IT IS ORDERED AND DIRECTED that a hearing will be held on this issue on January 8, 2007 at 1:30 p.m., the same time as the hearing on the Petition for Injunctive Relief. By the Court, ?r M. L. Ebert, Jr., Jaime D. Wassmer, Esquire Attorney for Plaintiff Darren J. Hoist, Esquire Attorney for Defendant bas EXHIBIT -5-?- In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION RUTHANN K. DREWETT ) Docket Number 0 0 8 5 4 S 2006 Plaintiff ) vs. ) PACSES Case Number 126108655 BRAD A. DREWETT ) Defendant ) Other State ID Number ORDER AND NOW, to wk on this 21ST DAY OF NOVEMBER, 2006 IT IS HEREBY ORDERED that the ® Complaint for Support or Q Petition to Modify or Q Other filed on SEPTEMBER 29, 2006 in the above captioned matter is dismissed without prejudice due to: THE DEFENDANT RESIDING IN THE HOUSEHOLD, PAYING THE TWO MORTGAGES ON THE MARITAL HOME AND OTHER HOUSEHOLD EXPENSES, AND PLAINTIFF HAVING INCOME FOR HER PERSONAL NEEDS. ® The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. BY THE COURT: Kevin . Hess, JUDGE DRO: R.J. Shadday Service Type M EXHIBIT ? r Form OE-506 Worker ID 21005 -Ti Co a C_3 ?^r .0000', JUN 2 9 2007 RUTHANN K. DREWETT, Plaintiff, V. BRAD A. DREWETT, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5701 : CIVIL ACTION - LAW IN DIVORCE ORDER th AND NOW, this ` day of 1.3 t y 2007, upon consideration of the forgoing petition, the Court grants Gerald S. Robinson, Esq., and the firm of Robinson and Geraldo, leave to withdraw as counsel for Plaintiff in this proceeding. Distribution: Gerald S. Robinson, Esq., 4407 North Front Street, Harrisburg, PA 17110, Attorney for Plaintiff 4 Ruthann Drewett, 129 Shady Lane, Enola, PA 17025 9 _ ng, o -7 Darren Hoist, Esq., 130 Walnut Street, P.O. Box 810, Harrisburg, PA 17101, Attorney for Defendant/ <:;'- " 5 6? :! 'Hd 9- IT LODZ ?: }C.,iYUluV2d 3Hi?O