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Home My WebLink About94-02368 ~i r- J co ~. rf); (0' v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE : q <+ - :l. ~ c., 1f ~ ;I-t,v..-.J : NO. CIVIL 1994 CHARLES TAYLOR, Plaintiff JANET (GLICK) TAYLOR, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the court. You are warned that if you fail to do so the case may proceed without you and a decree of divorce may be entered against you without further notice for the relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator, Cumberland County Courthouse, Carlisle, PA 17013, 717-240-6200. Date5 b /9r I / ,4~ />>1 /{Ja~ Lisa M. Wa~o~1 Student ttorney ~~ 1J1~ Thomas M. Place Robert E. Rains Linda E. Fisher Harvey A. Feldman Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 "'-.....# .,'a>'..''''T Charles Taylor Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY , PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE q <t - ~ 3 (", S C..~ ;:r. tfVy",-, : NO. CIVIL 1994 Janet (Glick) Taylor Defendant COMPLAINT UNDER 23 Pa.C.S. SECTION 330Ud) OF THE DIVORCE CODE The plaintiff, Charles Taylor, by his attorneys, the Family Law Clinic, sets forth the folIowing cause of action. 1. Plaintiff is Charles Taylor, who currently resides at 1954A, Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania, 17013. Plaintifrs mailing address is P.O. Box 285, Boiling Springs, Pennsylvania, 17007. 2. Defendant is Janet (Glick) Taylor, whose current residence is unknown. Her last known address was Fresno, California. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on November 24, 1971 in Fresno, California. 5. Plaintiff and defendant have lived separate and apart since May 1972. 6. There have not been any prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. ~" . WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. Date 4/JJY( 1r I R~ mu.)a~ Lisa M. Watson Student Allomey /J ' '~::l E. Ralt~ omas M. Place Robert E. Rains Linda E. Fisher Harvey A. Feldman Supervising Allomey FAMILY LAW CLINIC 45 North Pill Street Carlisle, PA 17013 717/240-5204 11 -- COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: SS. I verify that the statements made in this Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. fi4904, relating to unsworn falsification to authorities. ~v- CHA ES TAYLOR Date ~~/9jL #if!!'ll'!~!"'t'i~j~n_.";... ~ KAY 1\ 3 11 FH '9~ " vi'rflCE '.1, . 'I. \'WOil~Hr.Y CU"oli'c!,IW CCO!lTV hN'!5~..VMII.\ p.;&1. Gr. .JJ 3,J'. (} 0 .,--___: "'<l'~' ~-~'? -_.~..~ . ~ " " - . . t'. ....-.;; ~~ ~_..:.;......~.< r - r~' MAY 2 - f.fJ4 JJ. Charles Taylor Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY , PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE C; 't - :n(., [1 D.~ ::.r~,.-.. : NO. CIVIL 1994 Janet (Glick) Taylor Defendant ORDER OF COURT .I rl-l I. l../ AND NOW, this '1 day of , ,,," [l U ,1994 on consideration of the attached petitioner's Affidavit, leave is granted to the petitioner to proceed in forma pauperis to the extent that he is relieved of all costs in this action. By the Court, !rj(L'~~ (=. .~ J. HAY II 3 11 f'H '9~ , , , , 1': ~ ,-j.';.,' ;.\F,y . , r I ';',,; Y " .. , ,~ ':1. 1 i "4'!f" ' Charles Taylor Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Janet (Glick) Taylor Defendant : NO. CIVIL 1994 PETITION TO PROCEED IN FORMA PAUPERIS Charles Taylor, plaintiff in the above titled action, respectfully requests this Honorable Court to grant his leave pursuant to Pa.R.C.P. 1920.62 proceed in forma pauperis to the extent that he be relieved of all costs attendant to this action. Date 4- 'l{!,1y 't~ 77. tvk~ LI A M. WATSON Student Attorney /~ ~ ~);. /" . ~~~~~,~ TOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER HARVEY A. FELDMAN Supervising Attorney FAMILY LAW CLINIC 4S North Pitt Street Carlisle, PA 17013 717/243-2968 Charles Taylor Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Janet (Glick) Taylor Defendant : NO. CIVIL 1994 ATTORNEY'S AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS I, Lisa M. Watson, of the Family Law Clinic, student attorney for the party petitioning to proceed in fonna pauperis, certify that I believe petitioner is unable to pay the costs of instituting this action and that I am providing free legal service to petitioner. Plaintiffs Affidavit showing inability to pay the costs of litigation is attached hereto. Date if /~?J /9'1 ~,-JI1~~ I A M. WATSON Student Attorney ~J-i?O . t' ,,\1 t:.- . Ntl1~41 HOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER HARVEY A. FELDMAN Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 Charles Taylor Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE Janet Glick Taylor Defendant : NO. CIVIL 1994 AFFIDA VIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: The Petitioner, Charles Taylor, residing at 1954A Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania, 17013, upon his oath deposes and says: 1. I am the named plaintiff in the above titled civil cause of action and the defendant is Janet (Glick) Taylor. 2. This affidavit is made to inform the court as to my status of indigency and to request that the court grant me leave to proceed in this cause as an indigent. 3. In making this affidavit, I am aware that perjury is a felony and that the punishment is a fine of not more than $3,000 or imprisonment for not more than seven years or both. 4. I do not have any money on my person, at home, or elsewhere which could be used for the expenses of this proceeding. 5. I do not own real estate, personal property, or any other assets. I am not owed any amounts of money by any person. 6. My wife's, Janet (Glick) Taylor's, current residence is unknown. She is 43 years old. (a) I last lived with my wife, Janet (Glick) Taylor, in May, 1972. . . (b) I do not have information or knowledge as to whether my wife is employed, has any money, owns an automobile, owns real estate, or has any other personal property or assets. 7. My social security number is 569-92-1815. 8. I have the following income: Public assistance $130.00 per month $205.00 per month. Food stamps -------------------------------------------------------------------- Total Monthly Income $335.00 per month 9. My monthly expenses are as follows: Rent $50 per month Gas and automotive costs $40 per month Laundry $20 per month Replenishment of household items $25 per month Food (provided with food stamps) $130 per month Additional Food $20 per month (not covered by food stamps) Church Tithe $20 per month Physical Therapy $30 per month Total Monthly Expenses $335.00 per month 10. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 11. I verify that the statements made in this affidavit are true and correct. I understand .' r" ~~~~~'; ~'.'<~ , ' . . that false statements herein are made subject to the penalties of 18 Pa.C.S. G4904, relating to unsworn falsification to authorities. WHEREFORE, petitioner prays that this Honorable Court grant petitioner leave to proceed in forma pauperis in the above titled action without fee or cost to the petitioner. Date ~/:JX Ie; y- r--/ . ~ /' C[.~t"i, ~~ t--- CHARLES T A YLO .. "I Yri'>;~<:~ , . .." . " """"''':'v''':;_;,'~i;~;'::;W~~'~~::"':.t-,~"' ~}':-:'- .'.:.'.;..~.:...'.".::?;j;.~~.~,~.~,"~_- ';'~',:':.'~. >~~.'~:.":~, ~'~,"~.'_.~.'!k :~~..__"'". \ ... " _. ~ ."''''""~~~''' ... . . _,,,,,_,,,-_,-"'WC,"'-:-:""'~"-. ,:_.""..:-~.".'\t,,?,,,..,~~~,.!.~t;f........I"'''''''''7~.r!'~'\<i<''~'''JI'''I'-':':"-.1"'CcJ",,'.'"";-""~;"'o;.....-:~~~'''~-.''''-' . (f}) .- J . , . HAY II 3 11 PH '9~ , '.:' .;"rlcr ur i':r il,l'ifIOHGT^~Y Cu::rl:J., 1.!1il r,CUllT'( i'tN,,'j'fL'I,\NIA . -~ '-n '.' 1';;~ ~'.l ; "1 . Jci .~......._. " 'ln~ ....,';iIl: ->W"Noot__..."..-..---...-.--..---- 4o.._~ .. ~. .. " ll. . . , I t i . - -. l t ..,,:.~ !. ~.,~~-_. -.- I HAy 2 - W4 rJJ, CHARLES TAYLOR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE . : 'J 'f - .:n /.. ~ G'l..;1' ::T{''V)..--../ : NO. CIVIL 1994 JANET (GLICK) TAYLOR, Defendant ORDER OF COURT AND NOW, this 2 ~~ay of ""U 1994, on consideration of the attached Petition Pursuant to Rule 430 for Special Order of Court Directing Method of Service of Process, it is ordered that service of the Complaint in Divorce and Plaintiffs Affidavit under Section 3301(d) of the Divorce Code be made by publication of the attached notice, once in the Cumberland County Law Journal and once in the Carlisle Sentinel. Notice of the Intention to Request Entry of Divorce Decree is waived. By the Court, Jt~ E!k/ J. \ j 12 n\ '~ ~,~l \ HAY .11 1\,'",( ; :. ~, "' . . ',,', '., 0" ',\h~ '\".' (, ...: 1- , ',', \ CHARLES TAYLOR, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE v. JANET (GLICK) TAYLOR Defendant/Respondent NO. CIVIL 1994 PETITION PURSUANT TO RULE 430 FOR SPECIAL ORDER OF COURT DIRECTING METHOD OF SERVICE OF PROCESS Plaintiff/Petitioner, Charles Taylor, by his attorneys, the Family Law Clinic, requests this court to direct method of service by publication, once in the Cumberland County Law Journal and once in the Carlisle Sentinel, upon consideration of the following: 1. Petitioner. Charles Taylor, is the plaintiff in the above-captioned matter, who currently resides at 1954 A Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Respondent, Janet (Glick) Taylor, is the defendant in the above-captioned matter whose current address is unknown to the petitioner. Respondent's last known address was Fresno, California. 3. Petitioner and Respondent were married on November 24, 1971 at Fresno, California. 4. Petitioner and Respondent have lived separate and apart since May of 1972. 5. Petitioner has not seen or heard from the respondent since May 1972. 6. Petitioner filed the above-captioned Divorce Complaint at the Prothonotary's ",,:., ~,-,..~_._.,.., Office in the Cumberland Coun1y Courthouse. 7. Petitioner's present suit in divorce requests no other relief, economic or otherwise. 8. Petitioner engaged in numerous and extensive good faith efforts to locate the respondent, including the following: A. In 1989, Petitioner, made several phone calls to Michigan and California in an attempt to find a phone number or address for Respondent. The Respondent and her family were originally from Michigan. Petitioner was unable to locate Respondent or any relatives of Respondent. B. On March 8, 1994, Petitioner's student attorney, Lisa Watson, at the Family Law Clinic, contacted directory assistance in Muskegon, Michigan for a listing for Janet (Glick) Taylor. There was no such listing. C. On March 8, 1994, Petitioner's student attorney, Lisa Watson, at the Family Law Clinic, contacted directory assistance in Fresno, California for a listing for Janet (Glick) Taylor. There was no such listing. D. On March 8, 1994, Petitioner's student attorney, Lisa Watson, at the Family Law Clinic, contacted directory assistance in Fresno, California for a listing of any persons with a last name of Glick in an attempt to collect information as to the whereabouts of the Respondent. There was one such listing with no address available. Lisa Watson, student attorney, contacted that person by phone and was informed that he was not acquainted with the Respondent. E. On March 8, 1994, Petitioner's student attorney, Lisa Watson, at the Family Law Clinic, contacted directory assistance in Muskegon, Michigan for a listing of any persons with a last name of Glick in an attempt to collect information as to the whereabouts of i' :~ the Respondent. There were two listings for persons named Glick: Mr. Jeffrey Glick and Ms. Lisa Glick. F. On March 8, 1994 Petitioner's student attorney, Lisa Watson, at the Family Law Clinic, contacted the Post Office in Muskegon, Michigan and received addresses for Mr. Jeffrey Glick and Ms. Lisa Glick in Muskegon, Michigan. G. On March 8, 1994 Petitioner's student attorney, Lisa Watson, at the Family Law Clinic, mailed letters to Mr. Jeffrey Glick and Ms. Lisa Glick in Muskegon, Michigan requesting any information regarding the whereabouts of the Respondent. On March 18, 1994, Mr. Jeffrey Glick replied and informed the Family Law Clinic that he was not acquainted with the Respondent. H. On March 22, 1994 Petitioner's student attorney, Lisa Watson, at the Family Law Clinic, mailed a follow-up letter to Ms. Lisa Glick in Muskegon, Michigan requesting any information as to the whereabouts of the Respondent. On April 6, 1994 Ms. Lisa Glick replied and informed the Family Law Clinic that she was not acquainted with the Respondent. I. On April 21, 1994 Petitioner's student attorney, Lisa Watson, at the Family Law Clinic, contacted the California department of Motor Vehicles in Fresno, California in an attempt to secure the Respondent's address. In accordance with the California Confidentiality Laws the operator refused to disclose any information. . WHEREFORE, plaintiff/petitior.er requests that this Court enter an order directing service of the Complaint in Divorce under Section 3301(d) of the Divorce Code by publishing the notice attached hereto as Exhibit. A., once in the Cumberland County Law Journal and once in the Carlisle Sentinel. Respectfully submitted, Date ~-l..~-/Y ~ 1tJ.uJ(J~ isa M. Watson Student Attorney /'ifif.rj(' ;;"~ R ERT E. RAINS Supervising Attorney FAMILY LAW CLINIC 4S North Pitt Street Carlisle, PA 17013 717/240-5204 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: SS. I verify that the statements made in this Petition Pursuant to Rule 430 for Special Order of Court Directing Method of Service of Process are true and correct to the best of my personal knowledge and belief. 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: ~~/9V (7~~~? CHARLES TAR Charles Taylor Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE Janet (Glick) Taylor Defendant : NO. CIVIL 1994 ATTORNEY'S AFFIDAVIT SUPPORTING PETITION PURSUANT TO RULE 430 FOR SPECIAL ORDER OF COURT DIRECTING METHOD OF SERVICE OF PROCESS I, Lisa M. Watson, of the Family Law Clinic, student attorney for the party petitioning pursuant to Rule 430 for Special Order of Court Directing Method of Service of Process, certify that I believe petitioner is unable to locate the defendant. Plaintiffs Affidavit showing inability to locate the defendant is attached hereto. Date ~ - )..'r? - 'W c ~/~ ~;:,tI~7 LISA M. WATSON Student Attorney .7 TOMAS M. PLA E ROBERT E. RAINS LINDA E. FISHER HARVEY A. FELDMAN Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 r';"'-'!"'""""'-'~ ...,_,,_.j,_"r_~ " " ~r'-'~~_'--:.""...,. ilLY II 3 11 fll'9~ f ; ~,Et "O"',OE OF j~F HIO;ljO:;nA~Y C~~L[RL.UDCQUNrY 1'[!I1I$YL~AkIA '1I..~.t:f ",., ,~ -~_<f' ~llO- "--..__..~~ . . , ; . L \ I I I 'I' . . "', '. - .._~._- '.. .,. -,._..- .' .", .1';"-" ......- - " ~. '.- "--. r . OIARLES TAYLOR, fa lIIe Court of Common Piau of Cumberlaad COUIIIy, PellDl)'lvanla No.94-2368 Civil 19 94 CIVIL ACTlOO - LAW Plaintiff VI. JANEl' (GLIO<) TAYLOR, Defendant ----------- IN DIVORCE ____..EBIIFrTPF. Please file the attached Proof of Publication fran '!he Sentinel. -------- .. ------------------------------------------------------------------- To Lawrence Welker ::r 0 'n.t2.J... Lf I ~4 {eu~ Supervising Ally ROBERT E. RAINS Prothonotary c 19L!f .,.,."...------ -/, ~,~'~;tG?- Student All)' for Plaiotiff MICHELLE B. S'fOKES , '\' zO', .of ~ ,,, rOo Ii. r I · . . - - -- '. . \. ....d._...._~ ',- . No. 94-2368 Term, 1994 ~ ..... CHARLES TAYLOR, Plaintiff VI. J~ (GLIC<) TAYLOR, Defendant PRAECIPE Filed 19 MIOIELLE B. S'l'OKES StudentAtty ROBERT E. RAINS Supervisiall Ally The Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 717/240-5204 ,- -- " . . " '. r I PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. ss: Marian M. Welsh of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation In the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly Issued In said County, and that the printed notice or publication allached hereto Is exactly the same as was printed and published In the reular editions and Issues of THE SENTINEL on the following dates, vlz Copy of Notice of Publication --''-0 I May 25, 1994 j CHARLES TAYLOR. Plalnlltl IN THE COURT OF COMMON PLEAS OF CUMBERLANO COUNTY. PENNSYLVANIA Public Notice Y. Affiant further deposes that he Is not Interested In the subject matter of the aforesaid notice or advertisement, and that all allegations In the foregoing statement as to time, place and character of publication are true. CIVIL ACTION. LAW IN DIVORCE ~ANE (GLICK) TAYLOR. O,lendanl . NO. 94.2388 CIVIL 19;'- ~IllW.El!QAtiQ~~ II you wllh 10 defend. you mUllenler. writltft appearsnce personally or by ,nomeV and Iii: )'Our delen.'. or objections In writing with 11'1 court. You 8te wamed lhat Is you r.1I to dO 10 the ca.. may proceed withool you Bnd a ~ cree 01 divorce may be .ntered agaln'l ybu wlthot,ll IU,r1he, noliee for the relief r.que'led by the plalnll", You may 10lA money or propllfY or olher rlghlS imparl.nllo you. YOU SHOULO TAKE THIS PAPER TO YOUR LAWVER ~r ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SeT FORTH BE. LOW TO FIND OUT WHERE YOU CAN GET LEGAL HelP. Coul1 Administrator, Cumber. land County Courthouse, Cer1iate, PA 170'3 717-240-6200, "' CHARLES TAYLOR, PlalnUff ; , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSVLVANI" ~;7?m,u <'" ( -'1/ 6lu 6/7/94 Sworn to and subscribed before me this day of June ,19 94 8th Y. CIVil ACTION. LAW IN DIVORCE JAUET (GLICK) TAYlOR, Delendant 94.2368 Civil Term NO. CIVIL 1994 !11ll!m l1f ~ '0!zufu./ 1 ""'-'1 L- .J:lU2?U) 7 Notary Public My commission expires: AND NOW,lfuI 4th dayot May, 1994 on con. ,lderollon ollho 8nacholl Pelilion pursuanllo Rule 430 lor SpecIal Order 01 Couf1 Directing Method of Service of Procon, ills ordored(hal <;OJViCe ollhe Cump1ainl in DiVorce and Ptwn. IIlf's Alfld<lvtt under Section 3301(d) 01 tho Divorce Code ty made publication of lhe a'l. lached nollCf'. once Inlhe Cumber1and counly Law JournAl and onco '" Ihe Carlisle SenMeI NotIce olltlc Intf'nllon lu 'loquOSI Enlry 01 01- ~'orce oDCIC!' ,!,> ....ar...ed ~., ,.' f .. o. r' , . '" ...., " _, _ ' ~ fj ~ I..""...:;',; ~ ~'.-: ..' .' ," 1 ~5 , L_l.." -~.. _ . "'-"""~''''., ,,~ -""......,'" ''fIJIllTitis lJ., ......:....1.1;1. - . '''r\'Zi " J.~"" I ~-, , , " I,.: I 21. -\'.~ > "_~~;L .< ..- ',- ' .,-, .',' ." .",...... , <~ -../ , . II JUH Zl 9 00 ~~ '9~ : riel'. Qf 1 1I')Il~ai\Y Gt!l-',; . n r. r.t~' :4TY .'L!-i.l J'T.'.Al;'t, . . ~ " " --. ~".'" ;;'. '~:"-' .. ..., ""--. ~- ." ;;I .~--,.....__... " -or: \ , , J A N J 2 19 95 (p. CHARLES TAYLOR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA v. CIVIL ACTION . LAW IN DIVORCE JANET (GLICK) TAYLOR, Defendant NO. 94-2368 CIVIL 1994 ORDER OF COURT {iI AND NOW, this I ') day of ,J '-- -'- \ ll. ~.31995, upon consideration of the attached Petition for Leave to Withdraw, leave is granted to the petitioner, the Family Law Clinic, to withdraw as counsel for the plaintiff. By the Court, 1JCL~\ r~ . Ji-- J . I, 56. \',. t -, 1\ \' I Iiif .~,.A .~. .---...-.- -;.......-ii.4-~,~;. '''' -,. ,-........ ~."'--_..~ : .~'..;'.'i'" >';"'1;""'''' o. "'i!l.'" ,'.;, .:.:'.: .:-.... .,..""~l!t.,"~:,,_.. ...~.~.~,"""~.~}.. .~IlW:~~- :.1Mt~-~..,~.{- \ -.---- -_._- -~~-._._-~ @ ....-.................-.....~-_....~- -WIHfU " ~ - " 'J .-........- I' . i'-' ,~.,..-;~.., ." CHARLES TAYLOR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE JANET (GLICK) TAYLOR, Defendant NO. 94-2368 CIVIL 1994 PETITION FOR LEAVE TO WITHDRAW PURSUANT TO RULE I.I6(b)(4) OF THE PENNSYLVANIA RULES OF PROFESSIONAL CONDUCT Petitioner, the Family Law Clinic, hereby petitions for Icave to withdraw from further representation in this matter on behalf of Charles Taylor, pursuant to Rule 1. 16(b)(4) of the Pennsylvania Rules of Professional Conduct, and in support avers the following: I. Plaintiff, Charles Taylor through his attorneys, the Family Law Clinic, filed a Complaint in Divorce on May 4, 1994. 2. Plaintiff, through his attorneys, the Family Law Clinic, filed a Petition for Service by Publication which was granted on May 4, 1994. 3. The Notice to Defend and Claim Rights was published in The Sentinel on May 25, 1994. 4. Despite his promise to do so, the plaintiff failed to pay the publication bill. The Family Law Clinic has attempted to obtain payment from the plaintiff on numerous occasions. However, Mr. Taylor has ignored all such requests. The Family Law Clinic was forced to pay The Sentinel for the publication costs. 5. The Family Law Clinic has written several letters to the plaintiff in an attempt to move the case forward. However, the plaintiff has failed to respond to the petitioner's correspondence. ~' . 6. On several occasions the Family Law Clinic informed the plaintiff of the need for him to contact the Family Law Clinic in an effort to serve his legal intcrcsts. The plaintiff has not been in contact with the Family Law Clinic since July 1994. Hc has been given several chances to respond, and he has ignored all requests. On October 7, 1994, the Family Law Clinic informed the plaintiff that he had 30 days to contac\ this office before the Family Law Clinic withdrew from his case. The plaintiff he has not contacted the Family Law Clinic. 7. Since the plaintiff has failed to aid the Family Law Clinic in its attempt to move the case forward, there is nothing more the Family Law Clinic can do on the plaintiffs behalf. WHEREFORE, the Family Law Clinic requests permission to withdraw as counsel for Charles Taylor in the above captioned matter. Respectfully submitted, Date JI/lI'7tf / " ;((JA-.)? .7 (L)~I-" '/Lisa M. Watson Certified Legal Intern ~ /r'~ - homas ~e a~ Robert E. Rains Linda E. Fisher Thomas Peeler Supervising Attorneys The Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 717/240-5204 or 7171243-2968 1 j , ~ l,." ~. +..:,.... .,.. -Fe.. . ".: .. ,...,,', "..." .' ",...' :ri-'!;l~.\C:,'<.'.' ".-':, ,- ,,: ..,.. . ...,'..." ..:' .....(,........'\d :,. :J,.f~<:,'... ...<:.~}i r;,':<i\L"",,~"ili'!~:"""'iJ_';""" '" ._~ _ _ '~,,"_ .~ :{~:"':~~Y"r,\';}ii$Wi..E!-,,~"':_;F~"..-~Jtlil "~C~~",,,\':l"i';""Ij'_'':Il"}~-W:"''~'::'u .. \ ~~~._~ -------- -" .___v_" @ -'~'.>_~<(-:w,,:., '.~'~ ",-,:".,-,..", " " ., , _ ~ l1':'r ..".......- ~ . I.. ',- -, '_~.'_-4 " CHARLES TAYLOR, Plaintiff In tho Court or Common Plea or Cumberland COUIlly. POlllllylvanla 94-2368 No, CIVIL ACTION - LAW Civil 19~ VI. JANET (GLICK) TAYLOR, Defendant IN DIVORCE Praecipe to Withdraw Appearance Per the Court's Order of January 13, 1995, the Family Law Clinic hereby withdraws as counsel for the Plaintiff in the above-captioned matter. To Lawrence E. Welker Prothonotary 19.1Y' -rA tV d... '7 ...J I r I ~t ~~~:~llY o(b:1A -::JJ,1 t, )~ Li sa M. Wd tson Student Alty ror Plaintiff " ~.;. T t ,. Il , . . " " "0 \. , ,- No. 94-2368 CIVIL Term. 19 94 CHARLES TAYLOR, Plaintiff VI, JANET (GLICK) TAYLOR, Defendant .,: J~H L i \\ l.e ~;\ I~S PRAECIPB Filed 19 Lisa M. Watson StudenlAlly Robert E. Rains SupervisinB Ally The Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 717/240-5204 ,- - ,- . . . " JAN !!. j995cfr-- CHARLES TAYLOR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE JANET (GLICK) TAYLOR, Defendant NO. 94-2368 CIVIL 1994 ORDER OF COURT AND NOW, this /3-:1J...day of h ,1995, upon consideration of the attached Petition for Leave to Withdraw, leave is granted to the petitioner, the Family Law Clinic, to withdraw as counsel for the plaintiff. By the Court, /.51 ~ .t. ...u.~~ J TRUE C('f''t F~"N RECORD In 1, : , . :,,'/ h.md a:1~j Ih,.~ ~-..'I; I: . ,. ,,,' :: I :_.:, f1J. lhis 13-TJ.. dilY or _ fJ:::. '" 199.~. "..........,-:.Jb.<~( pro~~~~'.......... -' .. CHARLES TAYLOR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE JANET (GLICK) TAYLOR, Defendant NO, 94-2368 CIVIL 1994 PETITION FOR LEAVE TO WITHDRAW PURSUANT TO RULE 1.16(b)(4) OF THE PENNSYLVANIA RULES OF PROFESSIONAL CONDUCT Petitioner, the Family Law Clinic, hereby petitions for leave to withdraw from further representation in this matter on behalf of Charles Taylor, pursuant to Rule 1. 16(b)(4) of the Pennsylvania Rules of Professional Conduct, and in support avers the following: 1. Plaintiff, Charles Taylor through his attorneys, the Family Law Clinic, filed a Complaint in Divorce on May 4, 1994. 2. Plaintiff, through his attorneys, the Family Law Clinic, filed a Petition for Service by Publication which was granted on May 4, 1994. 3. The Notice to Defend and Claim Rights was published in The Sentinel on May 25, 1994. 4. Despite his promise to do so, the plaintiff failed to pay the publication bill. The Family Law Clinic has attempted to obtain payment from the plaintiff on numerous occasions. However, Mr, Taylor has ignored all such requests. The Family Law Clinic was forced to pay The Sentinel for the publication costs. 5. The Family Law Clinic has written several letters to the plaintiff in an attempt to move the case forward. However, the plaintiff has failed to respond to the petitioner's correspondence. . .- .. 6. On several occasions the Family Law Clinic informed the plaintiff of the need for him to contact the Family Law Clinic in an effort to serve his legal interests. The plaintiff has not been in contact with the Family Law Clinic since July 1994. He has been given several chances to respond, and he has ignored all requests. On October 7, 1994, the Family Law Clinic informed the plaintiff that he had 30 days to contact this office before the Family Law Clinic withdrew from his case. The plaintiff he has not contacted the Family Law Clinic. 7. Since the plaintiff has failed to aid the Family Law Clinic in its attempt to move the case forward, there is nothing more the Family Law Clinic can do on the plaintiff's behalf. WHEREFORE, the Family Law Clinic requests permission to withdraw as counsel for Charles Taylor in the above captioned matter. Respectfully submitted, Date 1/" /~tf I ,-:<:- ..::u-)? IIi' 7a.~(t\. "'Lisa M. Watson Certified Legal Intern ~ / r'~ ' - a/?~ homas ~e Robert E. Rains Linda E. Fisher Thomas Peeler Supervising Attorneys The Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 717/240-5204 or 717/243-2968 . '~'~~, ',)'":,,,:.:. ' ~,.._.., 't',..... ;',j ~,f 't. " ,,",',' . ,;;,:,.- .., '~-- - ., .'~ ,_\..' J~N 27 Illil AH '95 I,,; ,; r'C!' _,I. ,,',.,)' Ii Y .., ,) \ , . . ... " --.--