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Home My WebLink About06-6820 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOIS L. KAYLOR Plaintiff V. : NO. 06- &kAO Civil Term E. WILLIAM KAYLOR, JR., Defendant CIVIL ACTION - 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 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 800-990-9108 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. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. BY THE COURT: J. 2 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOIS L. KAYLOR Plaintiff V. NO. 06- 6AW Civil Term E. WILLIAM KAYLOR, JR. Defendant CIVIL ACTION - DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Lois L. Kaylor who currently resides at 2306 Foxfire Circle, Mechanicsburg, Cumberland County, Pennsylvania since in or around March 1984. 2. Defendant is E. William Kaylor, Jr. who currently resides at 242 Seabert Road, Myrtle Beach, South Carolina since on or about September 5, 2006. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The parties were married on August 30, 1980 in Camp Hill, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. Wherefore, Plaintiff requests the Court to enter a divorce decree under section 3301(c) of the Divorce Code. 0 Gfit,Gl?+ Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Plaintiff Date: November 27, 2006 2 VERIFICATION I verify that the statements made in the foregoing document 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. I? Lois L. Kaylor Date: 11) zS I oco N Q CT 2c CS OD (n ..J O r, Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOIS L. KAYLOR Plaintiff V. NO. 06-6820 Civil Term E. WILLIAM KAYLOR, JR. . Defendant CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. E. William Kaylor, Date: December ?? _, 2006 ? ? ? -r,,; t. ;.., ? ? ?-s-t -;- . y '.. ? ?-- ' r? { L? Yy ?? - S N l.? C?? _ -r. SA --?7 _ ?: .?.. ?? LOIS L. KAYLOR, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2006-6820 CIVIL TERM E. WILLIAM KAYLOR, JR., : CIVIL ACTION -LAW DEFENDANT : DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, E. WILLIAM KAYLOR, JR. Respectfully submitted, Bated: Jme _?_, 201}7 LAW FIRM OF SUSAN KAY Susan Kay Cange o Esquire PA I.D. # 64998 4010 Gienfinnan I e Mechanicsburg PA 17055 (717) 724-2278 P.C. rv % . • O Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg. PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOIS L. KAYLOR Plaintiff TO THE PROTHONOTARY: NO. 06-6820 Civil Term CIVIL ACTION - DIVORCE PRAECIPE Please withdraw the appearance of Theresa Barrett Male, Esquire on behalf of Plaintiff and enter the appearance of Lois L. Kaylor, pro se. V. E. WILLIAM KAYLOR, JR. Defendant Date: September 9, 2007 0?:-)obm_fJ-, Date:repterrrber ? , 2007 ZL:?= &- - Theresa Barrett Male 1 Kaylor 4LoiL' -.-;. o _x rn 1` C'n " ? Sandra L. Meilton, Esquire Quintina M. Laudermilch, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeiltonAdzmmglaw.com tlaudennilchO.&mmglaw.com LOIS L. KAYLOR, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. No. 06-6820 Civil Term E. WILLIAM KAYLOR, JR., (In Divorce) Defendant PETITION FOR EXCLUSIVE POSSESSION OF MARITAL RESIDENCE PURSUANT TO SECTIONS 3502(c) AND 3323(8 OF THE DIVORCE CODE AND NOW, this-3/ Vday of / Axr--1117 2008, comes Plaintiff/Petitioner, Lois L. Kaylor, by and through her counsel, Sandra L. Meilton, Esquire, of Daley Zucker Meilton Miner & Gingrich, LLC, and files the following Petition for Exclusive Possession of Marital Residence, and in support thereof avers as follows: 1. Plaintiff/Petitioner, Lois L. Kaylor (hereinafter referred to as "Wife"), an adult individual, who resides at 2306 Foxfire Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055 (hereinafter referred to as the "Marital Residence"). 2. Defendant/Respondent, E. William Kaylor (hereinafter referred to as "Husband"), an adult individual, who resides at 242 Seabert Road, Myrtle Beach, South Carolina 29579. 3. The Parties were married on August 30, 1980 in Camp Hill, Cumberland County, Pennsylvania. 4. A Complaint for Divorce was filed by Wife with the Prothonotary on November 29, 2006 at the above-referenced docket number. 5. Section 3502(c) of the Divorce Code states that "the 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." 6. Section 3323(f) of the Divorce Code states that "[i]n 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." 7. Husband moved from the marital residence on or about September 6, 2006 and moved to South Carolina into a house purchased by Husband in November 2005 with marital funds. 8. When Husband left the martial residence, Wife was left solely responsible for the mortgage, insurance, taxes and all bills associated with maintaining the marital residence. 9. Husband has engaged in behavior that subjects Wife to an atmosphere of tension, stress and conflict, as a result of which, Wife changed the locks on the marital residence. 10. Husband has demanded the keys to the home and the pass code to the garage door and has threatened to return to the martial residence. 11. As a result of Husband's threats, Wife is afraid of Husband and is in fear for her safety if he returns to the martial residence. 12. Unless Wife is permitted exclusive possession of the marital residence, the mental, emotional, and physical health and welfare of Wife will be compromised. 13. The above-captioned case and the issues raised in this Petition have not previously been presented or heard by this Honorable Court. 14. On March 28, 2008, Susan Kay Candiello, Esquire, counsel for Husband, was advised via fax and U.S Mail that this Petition was going to be filed. On March 31, 2008, Quintina M. Laudermilch, Esquire contacted Attorney Candiello via telephone in an effort to obtain concurrence for this Petition; however, Attorney Candiello did not concur with the filing of this Petition. WHEREFORE, Plaintiff/Petitioner respectfully requests the Court to enter an Order granting the Wife exclusive possession of the marital residence located at 2306 Foxfire Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055. Such exclusive possession shall be in effect until further agreement of the Parties or upon further Order of the Court. Respectfully Submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC Date: ?> L'?, / 1o g By: S dMAttorney I.D. No. 32551 Quintina M. Laudermilch, Esquire Attorney I.D. No. 94664 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorney for Plaintiff VERIFICATION I, Lois L. Kaylor, verify that the statements made in the attached document 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 Lois L. Kaylor, Plaintr f/Petitioner CERTIFICATE OF SERVICE AND NOW, this day of , 2008, I, Quintina M. Laudermilch, Esquire hereby certify that I have, on this day, served the within Petition for Exclusive Possession of Marital Residence, on counsel for Defendant, by depositing a copy of the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Susan Kay Candiello, Esquire 4010 Glenfinnian Place Mechanicsburg, PA 17055 Attorney for Defendant DALEYZ,UCKER MEILTON MINER & GINGRICH, LLC By: intina M. Laudermi ch, Esquire Attorney I.D. No. 94664 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 4.?u+ ?. ? 113-, a ' APR 0 4 Sandra L. Meilton, Esquire Quintina M. Laudermilch, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeiltonAdzmmglaw.com tlaudermilch(a) ,dzmmglaw.corn IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LOIS L. KAYLOR, Plaintiff CIVIL ACTION - LAW vi. E. WILLIAM KAYLOR, JR., Defendant No. 06-6820 Civil Term (In Divorce) RULE TO SHOW CAUSE AND NOW, this day of , 2008, upon consideration of the Petition for Exclusive Possession of Marital Residence, a Rule is issued upon Defendant/Respondent, E. William Kaylor, Jr., to show cause why said relief should not be granted. RULE RETURNABLE 070 DAYS FROM THE DATE OF SERVICE. Service shall be accomplished by first class mail to Defendant/Respondent or his counsel. J. VfNWASWd ,kiNno E£ :Z Wd 6- M 90OZ Atib? U vL G CHI jG Sandra L. Wilton, Esquire Quintina M. Laudermilch, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeiiton Adzmmgiaw.com tlaudennilch(a)dzmmglaw. corn LOIS L. KAYLOR, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. E. WILLIAM KAYLOR, JR., Defendant CIVIL ACTION - LAW No. 06-6820 Civil Term (In Divorce) PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: Plaintiff hereby files this Praecipe and withdraws the Petition for Exclusive Possession of the Marital Residence Pursuant to Sections 3502(c) and 3323(f) of the Divorce Code, which was filed in the above-referenced matter on April 3, 2008. DALEYZUCKER MEILTON MINER & GINGRICH, LLC Date: By: dra L. Meilton, Esquire Supreme Court ID #32551 Quintina M. Laudermilch, Esquire Supreme Court ID #94664 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorneys for Plaintiff CERTIFICATE OF SERVICE AND NOW, this Avkday of Z??y , 2008, I, Quintina M. Laudermilch, Esquire hereby certify that I have, on this day, served the within Praecipe to Withdraw, on counsel for Defendant, by depositing a copy of the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Susan Kay Candiello, Esquire 4010 Glenfinnian Place Mechanicsburg, PA 17055 Attorney for Defendant IDALEYZUCKER MEILTON MINER & GINGRICH, LLC By: Qu Quintina M. Laudermilch, Esquire Attorney I.D. No. 94664 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 ?' -> t-? c'"'? .j"1 f.:: _--? ""."° .- .. r_.., ?.. ? r ..?.! 54.3 ?`? ._?-C ... ?. Sandra L. Meilton, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeiltonaldzmmglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOIS L. KAYLOR, Plaintiff V. E. WILLIAM KAYLOR, JR., Defendant No. 2006-6820 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on November 29, 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. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. '?6 Date: (Ao Lo' L. Kaylor, Plait If c? Sandra L. Meilton, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeilton dzmmglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOIS L. KAYLOR, Plaintiff V. E. WILLIAM KAYLOR, JR., Defendant No. 2006-6820 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301 (e) AND 43301 (d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: " r J,-) ?60 A/) A kq4 IV) Lois L. Kaylor, Plai 't ff o r°,xs -c C t::1 W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOIS L. KAYLOR, Plaintiff V. E. WILLIAM KAYLOR, JR., Defendant No. 2006-6820 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on November 29, 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. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: ?-L 5 _0 g E. William Kaylor, Jr., Defe cant r Cry ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOIS L. KAYLOR, Plaintiff V. E. WILLIAM KAYLOR, JR., Defendant No. 2006-6820 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO 1. I consent to the entry of a final decree in 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 in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: E. William Kaylor, Jr., efendant -c " t _ =? ,..t ?? ? 1 _i F LOIS L. KAYLOR, VS. E. WILLIAM KAYLOR, JR., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 06-6820 CIVILTERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) (Strike out inapplicable section). 2. Date and manner of service of the complaint: Acceptance of Service by Defendant ; said Acceptance was filed with the Court on December 12. 2006. 4. Related claims pending: Norte . 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver' of Notice in §3301 (cj Divorce was filed with the Prothonotary: mailed to Prothonotary's office on 5/6/08 with this orm. Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: mailed to Prothonotary's office on 5/6/08 with this form., Attorney for Pla tiff / 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code; by plaintiff April 21, 2008 by defendant April 25, 2008 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LOIS L. KAYLOR VERSUS E. WILLIAM KAYLOR, JR. No. 2006-6820 DECREE IN DIVORCE AND NOW, If IS ORDERED AND DECREED THAT LOIS L. KAYLOR , PLAINTIFF, AND E. WILLIAM KAYLOR, JR. DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. PROTHONOTARY a,^ e .. ?.+