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HomeMy WebLinkAbout95-00875 --g o 3 cj -7 ] 3 c3 ~ F- J ~ ()O \ .' ~_a_~~_~~_~_~*~*****'*~*'~**'~--~ -. ~--~_.-- ,- - ---.-' "-"" ...,."", - ._, -... - --,- '.." -..." .----.--- 'i~ ~ ~ -.-_.__..... ~ll * IN ~I ~l THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~ STATE OF ~. PENNA, ~ ~ *; ~ * ~ IDRI J. A'lWJOD, N ll,q9.~-:o.~?s.q. ,...,..,........ 19 9S ~ plaintiff ~, Vt\I.~t1:-; * ROOOER T. A'lWJOD, II, * Defendant ~ " ~ ~ DECREE IN DIVORCE ANDNOW",~.,~"""", 19,.,9,6.,. it is ordered and ~l ':*1 ~l " ~ ,', * decreed that.. , .. , ,~~ .~~ .~~.. , . ., , ...., , .. , .. .... .. .., '. plaintiff, and, , "~, ~'" "~I, ;r;r, " , " " , , " , " " , " , "" " ,." ", defendant, are divorced from the bonds of matrimony_ ,"' ~ ~ '.' * ~ '.' ~ The court I'etains 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 .'.,."".".""",."""".""""."".'",.,...,..';7".'..".."". ? /: . " ""."."..,. . , , , , , , . . . . . , , , , , , . , , , , . . , , , , , . -,' ;:." , , ',1' , , , . . , , , . , , , . " 1;Jt/. I C'I t: ^lIe.I:~4.<.n<'~ Cl..?~-f, ;e..nK_~ J, ~9-l-ll .K~' c..2.7 ,f ~/ 'l7'r? Prothonotary ~ ~ ~ ~ ~ * ~ ~ :;' ~ :;' <It:- .~:. ':.' - -, ,- --~~- -, --. - - , ~ ~ **~****~*~.*~.*ro~,.~~.**~~.~ ~ ~ ',' ~ '.' * ,'. ~ ;i; ',' ~ '~ ~ ,:> ~ ~ ;t1 ... ~ ", ;it ... * .', ~ I, ~ -.' ~ ~ ... r~ ,:, ~ ~ ',' * ~ ~; * 1~ I: /':' j~ I... ~~ ~~ ! . I,', !:!o :~ .~ e ,~ ;* . IN THE COURT OF'COMMON PLEAS OF IDR! J. An-mo, . . ctJKBERLAND COUN'l'Y, PENNSYLVANIA Plaintiff . . . vs. . NO. 95-0875 CIVIL 1995 . . RODGER T. An-mo, II, . . IN DIVORCE Defendant . PRABC~PB ~ TRAHSM%T RECORD To the prothonotary: Transmit the record, toqether with the followinq information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(C) ~ of the Divorce Code. inapplicable section.) 2. Date and manner of service of the complaint: bv Sheriff's service on March 6. 1995 3. (Complete either paraqraph (a) or (b).) (a) Date of execution of the affidavit of 'consent (strike out required by Section 3301(c) of the Divorce Code: by the plaintiff: March 20. 1996 ; by Defendant March 7, 1996 . (b) (1) Date of execution of the Plaintiff's affidavit required by section 3301(d) of the Divorce Code: N/A (2) Date of service of the Plaintiff's affidavit upon the Defendant: N/A . 4. Related claims pendinq: none 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301(d) (l)() of the Divorce Code. IN 1lIE COURT OF CXX<<lN PLFAS OF aJMBERlAND COUNlY, PENNSYLVANIA CML AcrION - lAW 95-875 CIVIL TERM IN DIVORCE LORI J. A'lWOD, Plaintiff VB. RODGER T. AnmD, II, Defendant AMENJED <n1PLAINr IN DIVORCE GRIFFIE Be ASSOCIATES ATTORNEYS'AT-LAW 200 NORTH HANOVER STREET , CARLISLE, PA 17013 SUITE 550 14 NORTH MAIN STREET CHAMSERaSURG,PA 17201 nUQ 23 12 ~G PH '95 , 111,'OF"PlOl (}I . ii' (. -, ON r"~""., lij ~T"~V " ".",L/tI.ANO Ct:li/N TV "t"~;,nYM;i4 ~ 30. 00 1/' tilt,; ("2 elr) c)t it U )'1.-(, ~ tJ.-- .1 Y72. Y v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LORI J. ATWOOD, plaintiff RODGER T. ATWOOD, II, Defendant 95-875 CIVIL TERM 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 will proceed without you and a decree in divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, inclUding custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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. Court Administrator Fourth Floor Cumberland county Courthouse Carlisle, Pennsylvania 17013 (717) 240-6200 LORI J. ATWOOD, I IN THE COURT OF COMMON PLEAS OF Plaintitf . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. I CIVIL ACTION - LAW . . RODGER T. ATWOOD, II, . 95-875 CIVIL TERM . Defendant . IN DIVORCE . AM!lNDI!lD COMPLAINT IN DIVORCB 1. Plaintitf is Lori J. Atwood, an adult individual currently residing at 332 North College street, Carlisle, Cumberland county, Pennsylvania. Ms. Atwood has resided at this address for approximately three years. 2. Defendant is Rodger T. Atwood, II, an adult individual currently residing at the Federal Correctional Institution, Allenwood, Post Office Box 2000, White Deer, Union County, Pennsylvania. Mr. Atwood has resided at this address for approximately two years. 3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 17, 1992 in New Bloomfield, Perry County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United states of America or its Allies. 7. Plaintitt has been advised ot the availability ot counaelinq and the riqht to request that the court require the parties to participate in counselinq. Knowinq this, Plaintitt does not desire that the Court require the parties to participate in counselinq. 8. Plaintiff and Defendant are citizens of the United states ot America. 9. The parties' marriaqe is irretrievably broken. 10. Plaintiff desires a divorce based upon the beliet that Defendant will, ninety days from the date of the filinq ot this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to 23 P.s. Section 3301(c). COUNT II 11. Paraqraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. The parties have lived separate and apart since May, 1992, and have remained separated since that time. WHEREAS, Plaintiff requests your Honorable Court to enter a Decree in Divorce under Section 3301 Cd) of the Divorce Code of 1980, as amended. COUNT II I 13. Paragraphs 1 through 12 are incorporated herein by reference as if set forth in their full text. 14. Defendant has committed such indignities upon the person of the Plaintiff, the innocent and injured spouse, as to make her condition intolerable and life burdensome. WHEREFORE, plaintiff requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. 3301(a)(6) of the Divorce Code of 1980, as amended. COUNT IV 15. Paragraphs 1 through 14 are incorporated herein by reference as if set forth in their full text. 16. The Defendant has been sentenced to imprisonment for a term of two or more years upon conviction of having committed a crime. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to section 3301(a) (5) of the Divorce Code of 1980, as amended. COUNT V 17. Paragraphs 1 through 16 are incorporated herein by reference as if set forth in their full text. 18. Plaintiff is unable to provide for or afford her counsel fees, expenses and costs during the pendency of this divorce action and through its resolution. 19. Plaintiff is without sufficient property and otherwise unable to financially support herself despite being employed. 20. Defendant has access to sufficient funds and is able to pay for counsel fees, expenses and costs as well as alimony and alimony pendente lite for Plaintiff. 21. The Detendant, who i. incarcerated, has tiled a claim tor economic reliet, knowing that there are no economic aspects ot this case that need to be resolved I thus, creating additional expense tor the Plaintitt which is unnecessary and groundless. WHEREFORE, Plaintitt requests your Honorable Court to enter an Order requiring Detendant to pay Plaintitt's counsel tees, expenses, and costs as well ae providing tor payment ot appropriate alimony and alimony pendente lite to Plaintitt. Respecttully submitted, GRIFFIE & ASSOCIATES re w ,-- -'-'-".-"- --:-.....".....-. .~ - ..~.. VB. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-0875 CIVIL TERM IN DIVORCE LORI J. ATWOOD, plaintiff RODGER T. ATWOOD, II, Defendant AP~IDAVIT O~ CONSBNT 1. A complaint in Divorce under Section 3301(C) of the Divorce code was filed on February 11, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. , 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to reauest entrv of the decrees. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: (}1 " r <. f... 7 I I "I tt G, ~ /:" /JJt~-P; RODG T. ATWOOD, II Defendant n ,-' ~:. \..;") 0\ o -n ..- ....... ~!..:.: -~ ~1: .,,::rl . ,- .--..,m "'9 . '6 ":::-11 :-:;:0 ,-.0 om ..I ....)0. :J:J -< ....-:-.. (t}-'~l ' ~.?[ C,';:.. r';C -. ~~;,.:~, ~. .~ ~-j -. - -:'7 :!.: - .. o ". .. 95-0875 95 Tam, It___ LORI J. ATWOOD. plaintiff -' -- ... RODGER T. ATWOOD, II, rw . . ~ - Defendant I'JLASCI'S It . All', (~ ,,., (') co, c.n '" -'0 i ~.., ..J r: i! -...-J '::rl ~~; . "p-- ~ .,m (.:~ .- ,~'? ~~{ : ~o 3 '3:] "', co. 'j~ ':'~l- :t.e:: - i'^) .. ::", .' 0 -. --; ~'1 -. N -. () ,~ .~... e- "' -" w.... .. "tl -, 91. ~:: ~ ~~., j';;D ;.:.J "rn :';: ~ ~-'~~6 (fl': ~~~\ -. ~." -~~ ">)5 , " -," .~" "' t::-: ~. - ~':;ni ".,.I'!_. .. ::.:;' ...~_. 0 :~ --J ", w -. C" '.:;.~ \./) 0 c,."\ ".\ :'~ ':-\ ''''_n ,on ';,0 :,l:;:" :--, .,.,.\~ 0 .., ",,:.,0 :s ::,:!r\ .' .:p, - .',.:', .\ :::~ (~, ':.f! \'V -- -...,;'~. ~:~:~~'; .--T' .. ~ \r r... _ ,'~' ::...' '~. ." -' f3 LORI J. ATWOOD, . IN THE COURT OF COMMON PLEAS OF . plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . VB. . CIVIL ACTION - LAW . . . RODGER T. ATWOOD, II, . NO. 95-0875 CIVIL TERM . Defendant : IN DIVORCE WArVBR 01' 1I0TrCI!l O~ rNTBNTION TO RJlOOI!lST I!lIlTRY O~ A DrVORCII DI!lCRJlI!l ONDI!lR SBCTrON 3301'C) 01' TBII DrVORCI!l CODII 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lOBe rights concerning alimony, division of property, lawyer's fees or expenses if r 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 BtatementB herein are made subject to the penalties of 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. DATE: , ?-/7' 7(;. ~:( ~ d~' ' / LORI J. ATWOOD,( , ~ Plaintiff ~i..~ t."..";J ,.., C' C:l' ;" , .,.. .. -,... :"J (" \. .- ..'. :!1 , .It~ -/.' ;..:> '~~ ~;~- 0 -.:~o ::~ .,\ -' ."'1 t:::~; r -' 1,J -;.;. . - , -;\,1\ ~- ., ~ ....~ -' c.) '~'i -. (..0) 0' .' .. LORI J. ATWOOD, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. RODGER T. ATWOOD, II, DEFENDANT 95-0875 CIVIL TERM IN DIVORCE ORDER OF COURT AND NOW, this 5th day of October, 1995, defendant, Rodger T. Atwood, II, having raised economic claims for relief In the above-captloned divorce case, and plaintiff, Lori J. Atwood, having filed a petition to bifurcate the divorce from the economic claims upon wh,lch a hearing has been set for Monday, October 23, 1995, and defendant having not filed a consent to either the bifurcation of the divorce or the entry of a final divorce decree, the request of defendant to exempt his presence at the hearing on a writ of habeas corpus ad subjiciendum, IS DENIED. By the....ooun, /;~ / " /:/' ,h v' , (/ Edgar B. Bayley, J. " Bradley L. Griffie, Esquire For Plaintiff _ ~~ /0/5/9:;"' ~,-f. Rodger T. Atwood, II, Pro se 06454-087 FCI Allenwood P.O. Box 2000 White Deer, PA 17887 :saa r ;' . . t:~"" \; ~ l: . (.,: ;: \, . i;},J. ',' , 56. II j IlS Z t: 130 r J-' ~ , ~',: ~ ~,.' ~.' . 'J .~. . , ,~ LORI J. ATWOOD Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : CIVIL ACTION - LAW : 95-0875 CIVIL TERM : IN DIVORCE RODGER T. ATWOOD Defendant PETITION FOR COURT ORDER AND NOW, comes Petitioner, Rodger T. Atwood II, pro se, and petitions the court as follows: reminder of Plaintiffs infidelity (i.e., her pregnancy to another) in your Honorable Court (b) Defendant does not wish to waste your Honorable Courts time or money. (c) Defendant is currently studying for a degree in Computer Science and his appearance would disrupt those studies. (d) Defendant would suffer many hardships within the Federal Prison System by having to appear (i.e., loss of job,loss of cell, etc.) 1. Your Petitioner is the above named Defendant, Rodger T. Atwood II, an adult individual currently incarcerated at the Federal Correctional Institution, Allenwood, Post Office Box 2000, White Deer, Union County, Pennsylvania. 2. Petitioner respectfully requests your Honorable Court to exempt Defendant from Writ of Habeas Corpus Ad Subjiciendum for the following reasons: (a) Defendant does not want to be confronted with the stark --. ~ ! f \ \ ~ C <:t..., S" 1;,;."1-" .. ;,; = M ... ..r;.. --" 'r- q'~ '~_l ~~ \:':";:; 0:. ~"':)~LC) ;;': "'...:j r"'1 - ... ~.<l-' ..:; E o <D ~ ::x: - ~ '. . r LORI J. ATWOOD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. RODGER T. ATWOOD, II, Defendant 95-875 CIVIL TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301ldl OF THE DIVORCE CODE 1. Check either (a) or (b): ~ I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (11) or both): (i) The parties to thiB action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lOBe rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-affidavit are true and correct. I undertand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: /~-d- -95 ~T~ Defe ant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. ',j ; .~ i = I n ~ - , I .' -'. = e. I <D ~ :c: - I <..0 c.n ,:: ..;;' ',1 ,_ ,,;,r_; " r'::'.-; ,"- .. '.. ~::>j;:? : '~j if' ....t.-' :; .1" ..; , i I ~. - '._-..- .-.--.. ',. .# LORI J. ATWOOD, . IN THE COURT OF COMMON PLEAS OF . plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. CIVIL ACTION - LAW . . RODGER T. ATWOOD, II, 95-875 CIVIL TERM Defendant . IN DIVORCE . COUNTER-AFFIDAVIT UNDER SECTION 3301(dl OF THE DIVORCE CODE 1. Check either (a) or (b): ~ I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to thiB action have not lived Beparate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in thiB counter-affidavit are true and correct. I undertand that false statementB herein are made subject to the penalties of 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. Date: It) -J. -95 ~ 7: IHiInnkI ~ Defe ant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. ~ OCi 0 4 \99) ff- IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA LORI J. ATWOOD Plaintiff . . VB. : CIVIL ACTION - LAW . . I , I l. I: , I RODGER T. A'IWOOD : 95-0875 CIVIL TERM Defendant : IN DIVORCE PETITION FOR COURT ORDER AND NOW. comes Petitioner, Rodger T. Atwood II, pro se, and petitions the court as follows: 1. Your Petitioner is the above named Defendant, Rodger T. Atwood II. an adult individual currently incarcerated at the Federal Correctional Institution, Allenwood, Post Office Box 2000, White Deer, Union County, Pennsylvania. 2. Petitioner respectfully requests your Honorable Court to allow the withdrawal of his previously filed Counter-Affidavit under Section 330l(d) and to accept the enclosed Counter-Affidavit in its place. 3. Petitioner by the enclosed Counter-Affidavit consents to a Final Decree of Divorce. .. LORI J. ATWOOD, plaintiff . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. RODGER T. ATWOOD, II, Defendant 95-875 CIVIL TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301Cdl OF THE DIVORCE CODE 1. Check either (a) or (b): ~ I do not oppose the entry of a divorce decree. (~) I oppose the entry of a divorce decree because (Check (i), (11) or both): (i) The parties to thiB action have not lived Beparate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lOBe rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-affidavit are true and correct. I undertand that false statementB herein are made subject to the penalties of 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. Date: /0 --'- - 9< ~,_ T (jz,mn'f7) ~ Def~;;ctXnt NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. . Qel 0 4 ,g95~f LORI J. ATWOOD Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW 95-0875 CIVIL TERM : IN DIVORCE vs. RODGER T. ATWOOD II Defendant PETITION FOR COURT ORDER AND NOW, comes Petitioner, Rodger T. Atwood II, pro se, and petitions the court as follows: 1. Your Petitioner is the above named Defendant, Rodger T. Atwood II, an adult individual currently incarcerated at the Federal Correctional Institution, Allenwood, Post Office Box 2000, White Deer, Union County, Pennsylvania. 2. Petitioner respectfully requests your Honorable Court to issue an Order directing Plaintiff to turn over all pre-marital property (most of which is personal in nature), that was stored at her Mothers residence upon Defendants incarceration, to Defendants brother, Jamie J. Atwood. 3. Defendant fully expects Plaintiffs cooperation in returning Defendants property and has received no indication from Plaintiff to contradict those expectations. Petitioner asks for this Order to prevent any difficulties from arising in the return of property 4. Petitioner submits and attaches a listing of the afore- mentioned property with this petition . LORI J. ATWOOD Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW VB. . . RODGER T. ATWOOD II Defendant 95-0875 CIVIL TERM : IN DIVORCE LISTING OF PRE-MARITAL PROPERTY 1. ONE WASHER AND DRYER 2. ONE CANNON CAMERA W/3 LENSES 3. ONE VCR 4. ONE ANTIQUE MIRROR (4FT. X 5FT.) 5. ONE ANTIQUE WASH TUB 6. ONE ANTIQUE ROUND OAK TABLE W/4 7. 40 SWEATERS 8. 20 PAIRS JEANS 9. 4 COATS (1 BR. LEATHER) 10. ONE REMINGTON WORK BOOTS U. 50 SHIRTS 12. ONE WALLET (BLACK) 13. 12 TOWELS 14. THREE PAIRS SHOES :I: 15. ONE KINGSIZE WATER BED 16. ONE DRESSER 17. BLANKETS 18. SUITCASES (CLOTHES INSIDE) 19. DISHES, SILVERWARE, POTS & PANS 20. CROCKS ETC. 2l. SNOWBOARD 22. SNOW SHOES/TRAPS/STRETCHERS 23. ONE DIAMOND RING (1 CARAT) 24. ONE WEDDING BAND 25. ONE CORNER CABINET 26. NUMEROUS MISC. ITEMS CHAIRS **AT LEAST 30 MISCELLANEOUS BOXES WHICH CONTAIN ANTIQUE TOYS, BOOKS, PAPERWORK, AND OTHER PERSONAL ITEMS. ** LORI J. ATWOOD Plaintiff ~ "fj 't'lCT (', 1:4\)," 'LJ ....,. "'..'-.'- IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-0875 CIVIL TERM IN DIVORCE vs. RODGER T. ATWOOD II Defendant PETITION FOR COURT ORDER AND NOW, comes Petitioner, Rodger T. Atwood II, pro Be, and petitionB the court as follows: 1. Your Petitioner is the above named Defendant, Rodger T. Atwood II, an adult individual currently incarcerated at the Federal Correctional Institution, Allenwood, Post Office Box 2000, White Deer, Union County, Pennsylvania. 2. Petitioner respectfully requests your Honorable Court to issue an Order directing Plaintiff to turn over all pre-marital property (most of which is personal in nature), that was stored at her Mothers residence upon Defendants incarceration, to DefendantB brother, Jamie J. Atwood. 3. Defendant fully expects Plaintiffs cooperation in returning Defendants property and has received no indication from Plaintiff to contradict those expectations. Petitioner asks for this Order to prevent any difficulties from arising in the return of property 4. Petitioner submits and attaches a listing of the afore- mentioned property with this petition . LORI J. A1.'WOOD Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-0875 CIVIL TERM IN DIVORCE VB. RODGER T. A1.'WOOD II Defendant LISTING OF PRE-MARITAL PROPERTY 1. ONE WASHER AND DRYER 22. SNOW SHOES/TRAPS/STRETCHERS 2. ONE CANNON CAMERA W/3 LENSES 23. ONE DIAMOND RING (1 CARAT) 3. ONE VCR 24. ONE WEDDING BAND 4. ONE ANTIQUE MIRROR (4FT. X 5FT.) 25. ONE CORNER CABINET 5. ONE ANTIQUE WASH TUB 26. NUMEROUS MISC. ITEMS 6. ONE ANTIQUE ROUND OAK TABLE W/4 CHAIRS 7. 40 SWEATERS 8. 20 PAIRS JEANS 9. 4 COATS (1 BR. LEATHER) 10. ONE REMINGTON WORK BOOTS 11. 50 SHIRTS 12. ONE WALLET (BLACK) 13. 12 TOWELS 14. THREE PAIRS SHOES :i: 15. ONE KINGSIZE WATER BED 16. ONE DRESSER 17. BLANKETS 18. SUITCASES (CLOTHES INSIDE) 19. DISHES, SILVERWARE. POTS Ii PANS 20. CROCKS ETC. 2l. SNOWBOARD **AT LEAST 30 MISCELLANEOUS BOXES WHICH CONTAIN ANTIQUE TOYS, BOOKS, PAPERWORK, AND OTHER PERSONAL ITEMS. ** . . ,. t) ~ \\}9~ tk- 0(,' LORI J. ATWOOD Plaintiff IN THE COURT OF COHMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-0875 CIVIL TERM : IN DIVORCE VS. RODGER T. ATWOOD II Defendant PETITION FOR COURT ORDER AND NOW, comes Petitioner, Rodger T. Atwood II, pro se, and petitionB the court as follows: 1. Your Petitioner is the above named Defendant, Rodger T. Atwood II, an adult individual currently incarcerated at the Federal Correctional Institution, Allenwood, Post Office Box 2000, White Deer, Union County, Pennsylvania. 2. Petitioner respectfully requests your Honorable Court to issue an Order directing Plaintiff to turn over all pre-marital property (most of which is personal in nature), that was stored at her Mothers residence upon Defendants incarceration, to Defendants brother, Jamie J. Atwood. 3. Defendant fully expects Plaintiffs cooperation in returning Defendants property and has received no indication from Plaintiff to contradict those ex~ectations. Petitioner asks for this Order to prevent any difficulties from arising in the return of property 4. Petitioner submits and attaches a listing of the afore- mentioned property with this petition .......-.. LORI J. ATWOOD Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW VB. RODGER T. ATWOOD II Defendant : 95-0875 CIVIL TERM IN DIVORCE LISTING OF PRE-MARITAL PROPERTY 1. ONE WASHER AND DRYER 22. SNOW SHOES/TRAPS/STRETCHERS 2. ONE CANNON CAMERA W/3 LENSES 23. ONE DIAMOND RING (l CARAT) 3. ONE VCR 24. ONE WEDDING BAND 4. ONE ANTIQUE MIRROR (4Fr. X 5Fr.) 25. ONE CORNER CABINET 5. ONE ANTIQUE WASH TUB 26. NUMEROUS MISC. ITEMS 6. ONE ANTIQUE ROUND OAK TABLE W/4 CHAIRS 7. 40 SWEATERS 8. 20 PAIRS JEANS 9. 4 COATS (1 BR. LEATHER) 10. ONE REMINGTON WORK BOOTS 11. 50 SHIRTS 12. ONE WALLET (BLACK) 13. 12 TOWELS 14. THREE PAIRS SHOES % 15. ONE KINGSIZE WATER BED 16. ONE DRESSER 17. BLANKETS 18. SUITCASES (CLOTHES INSIDE) 19. DISHES, SILVERWARE, POTS & PANS 20. CROCKS ETC. 21. SNOWBOARD **AT LEAST 30 MISCELLANEOUS BOXES WHICH CONTAIN ANTIQUE TOYS, BOOKS, PAPERWORK, AND OTHER PERSONAL ITEMS. ** ~-*~-~-~~~~~-~~~---~-,),,~:~~,:_,;~~,~~:~~ $ - --- 3 ~ $ * IN THE COURT OF COMMON PLEAS ~ . $ 8 $ e ~ ~ ~ s " ... s ~ '.' ~ ',' s " s ~ s ~l ',' ~ .'. s ~ ~ ~ ~ ',' .. I .. , ~ " ... e 8 $ 8 ~ 8 '= ". 8 ~ ~ '.' !, " ... s ,.:j ~ s " ~ ~ ~.' ~ ~, ,', ~ ~ ~ $. ',' *- ',' ~ ',' I~ ',' ~ ~ ~ ',' ,~ i' .... A.. ~ Ilest: J. "" '.~ ~ " . !'-JJ <:I, Prothonotary ! ',' !'. to', ~ i~ ~ ___~__ _ __,v_,_ .....,. ",' . ,- ..~- ..." , '" ,,, ..., ' . ~ ~~~~_~~~~_~-~-*****-~*~****ro** OF CUMBERLAND STATE OF '* COUNTY PENNA, LORI J. A'ThUJD ,,""',',',','" ",,) ,"'" Plaintiff !\ N I J. ,.??::-,?7.~..,..9Y!1-..,..,...., 1995 ., Venms RODGER T. A'rnOOD II) ,,"'" ,,'. ,,"," ,) "., " Defendant DECREE IN DIVORCE AND NOW. ,.!ll[)f:.. .. .......' .. .. , .. ..... 19,95..,. it is ordered and decreed that.. ,lAr::I. ,J....A~"!QO.d... ..' .. .., ...... ................, plaintiff. and,.." ,~~gf!!;',~~,i;\~~~I.~~"',..,"',.....,"',........'" 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; w. ',' ~ s None ........ " ...... .......................... ......... ......... ,.. ...........1 s .................. .., .......... ...... ............ .......... " ............. $. '.' M .' D y Th" Co u r t : ~ p '" <;, ~ ,,, . , i\ WRI J. AnmO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-875 CIVIL TERN VB. RODGER T. AnmO, II, Defendant PRABCYPB TO TRAHSH%T 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 (Strike out section llSlO(k~lClt 3301(d) (1) of the Divorce Code. inapplicable section.) 2. Date and manner of service of the complaint: by Sheriff's Service on March 6, 1995 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by section 3301(c) of the Divorce Code: by the Plaintiff: N/A N/A ; by Defendant (b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301(d) of the Divorce Code: February 3. 1995 . (2) Date of service of the Plaintiff's affidavit upon the Defendant: March 6. 1995 . 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301(d)(1)() of the Divorce Code. By Union County Sheriff's service on April 6. 1995 ~~p~aintiff) ~(~~IlBm) Bradley L. Griffie, . . ." ",0 c:~ ~J:X: ...4 "1ft' . ;;r."t'"'l'" .... ".I.' t- ,,if- -, n' _-;~.;! c.' r;.J- . t..I::r:t~ .... . W! ~~;;~ I..,..()C') :..1.-. ~r~ _.J.*- ...'" ... ~ :0: ~ N c en ~ ~ IN TIlE COURT OF CGMJN PLFAS OF CUMBElU.AND COUN'IY, PEMlSYLVANIA CML AcrION - lAW 95 - 1J 1 S CIVIL 'I'E>>I IN DIVORCE ~-'1 ~ LORI J. ATh'OOD, Plaintiff FE8 /7 , Ji PH 'S5 I 'u [j,onIOf OF THE "hllflfONOr CUMllCRtAHIl C. (I; AM' rEfi~mV~HI4I1rr va. RODGER T. ATh'OOD, II, Defendant -if. /7.), J.:J:!. S, - P'"4" /. ,. ~t-) COMPlAINl' IN DIVORCE GRIFFIE & ASSOCIATES ATTORNEYS-AT-LAW 200 NORTH HANOVER STREET CARLISLE, PA 17013 SUITE 307 14 NORTH MAIN STREET CHAMBER5BURG. PAl7201 . LORI J. ATWOOD, Plaintiff . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 95- 8?5'" CIVIL TERM : IN DIVORCE RODGER T. ATWOOD, II, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been Bued in court. If you WiBh to defend againBt the claimB set forth in the following pages, you must take prompt action. You are warned that if you fail to do BO, the case will 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 righte important to you, including custody or viBitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the First Floor, CUmberland County Courthouse, South Hanover Street, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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. Court Administrator cumberland County Courthouse South Hanover Street Carlisle, Pennsylvania 17013 (717) 240-6200 " LORI J. ATWOOD, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95- 875' CIVIL TERM IN DIVORCE RODGER T. ATWOOD, II, Defendant COMPLAINT IN DIVORCE 1. Plaintiff iB Lori J. Atwood, an adult individual currently residing at 332 N. College street, Carlisle, cumberland County, pennsylvania. Ms. Atwood has lived at this residence for approximately three years. 2. Defendant is Rodger T. Atwood, II, an adult individual currently residing at the Federal Correctional Institution, Allenwood, Post Office Box 2000, White Deer, Union County, Pennsylvania. Mr. Atwood has lived at this residence for approximately two years. 3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 17, 1992, New Bloomfield, Perry County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The parties are not active members of the Armed Forces of the United states of America or its Allies. 7. plaintiff haB been adviBed of the availability of counseling and the right to requeBt that the court require the partieB to participate in counBeling. Knowing this, Plaintiff does not desire that the Court require the partieB to participate in counBeling. 8. plaintiff and Defendant are citizens of the united states of America. ~. The partieB' marriage is irretrievably broken. 10. plaintiff desires a divorce and it is believed that Defendant will after ninety (90) days from the date of the filing of this Complaint consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce under section 3301(C) of the Divorce Code of 1980, as amended. COUNT II 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth In their full text. 12. The parties have lived separate and apart since May, 1992, and have remained separated since that time. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce under Section 3301(d) of the Divorce Code of 1980, as amended. COUNT III 13. Paragraph 1 through 12 are incorporated herein by reference as if set forth in their full text. 10 14. Defendant haB committed such indignitieB upon the person of the Plaintiff, the innocent injured BpouBe, aB to make hiB condition intolerable and life burdenBome. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce purBuant to 23 P.S. section 3301(a)(6). re I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING COMPLAINT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. "' DATE: r:J - ..j> - 9'..s '-/~$--Y' /"1 r , 'LORI }. A OOD, plainti f VB. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95- CIVIL TERM IN DIVORCE LORI J. ATWOOD, Plaintiff RODGER T. ATWOOD, II, Defendant NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in thiB affidavit, you must file a counter-affidavit within twenty daYB after this affidavit has been served on you or the BtatelllentB will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in May, 1992 and have continued to live separate and apart since that time. 2. The marriage is irretrievably broken. 3. 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. I verify that the statements made in this affidvait are true and correct. I understand that false statementB herein are made subject to the penalties of 18 Pa.C.S., section 4904 relating to unsworn falsification to authorities. Date: cf. ?-9 c:;- ~:-~/ r-;1A~d)/ LORI J. AT,KOOD .... ... LORI J. ATWOOD, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-875 CIVIL TERM IN DIVORCE VS. RODGER T. ATWOOD, II, Defendant AY.IDAVIT O. BBRVICB 4\ - Donald N. Everitt SnERlPp 01' UNION COUNTY LEWISBURO, PENNA, 17837 875/95 NOTICE AND COMPLAINT IN DIVORCE LORI J. ATWOOD VS RODGER ATWOOD, II I hereby certify and return that on March 6, 1995 at 11:03 a.m., EST I served the within named defendant, RODGER17 ATWUUD, 11, by handing to him personally a true copy of the within Notice and Complaint in Divorce, at LCI Allenwood, Gregg Township, Union County, PA and made known unto him the contents thereof. So Answers, oIJCI'-<Lcut. 1~,':{J.l.IL. DONALD N. EVERI~~~heriff Costs:$28.25 Paid ., COlllDODWea1 tIi of Penn&lw .~ Counq of Dlllon,.,., D1I ':,~:;.~ " SWOrD :to and llu1iocrlbod: 'be'rorG ..; thlll G'v, d!l1 ot ,"~""" J.QQ.C'J .,1 C. ,^,'-.~~~... C:~'~~(::R''''l Prothonot~, " .~~, ..., , ','Sl'.l>.-.~'---' '" Corsl.sloll aplre. "_,..,~-,~, 0... '.:.:t Cllkl)TAlLHOWt DcpuIyPrnlhonol'l'/lam.otc.... I t.t..;,burs, Unl.. Counl\l PA ': f.( ,'minior, up1r" IstUor:J.n 1998 \-.r1 L:U ''-I ~ TO: The Court of Common Pleas of Cumberland County, Pennsylvania FROM: Rodger T. Atwood,II, Defendant RE: Civil Action - Law 95-875 Civil Term May it please the court to accept the following letter as a Counter- Affidavit to an action received by me on 03/06/95 from your Court. I am a layman, and therefore plead for the court's forbearance concerning my knowledge pertaining to the law. I am a Federal Inmate, currently incarcerated at the FCI Allenwood Medium Facility and an therefore at a greater disadvantage in answering a Civil or Criminal action, being unable to avail myself of outside, professional legal assistance. I am presently unable to afford an attorney, nevertheless feel compelled to make at least a feeble attempt to answer the above referenced civil action. ~7 The Plaintiff (Lori J. Atwood) and I were married on 3/01192, with the knowledge that there was a very great possibility that I would shortly receive a Federal Prison Sentence. I was incarcerated on 5/7192, approximately two months ,after our marriage. Because I believe strongly in the sanctity of marriage and that it's an act performed before God, I hereby contest this Divorce action and beseech the court to recommend counseling. Enclosed please find a copy of a letter to me from my wife, postmarked Nov. 15, 1994. In this letter she confesses to an adulterous affair, assures me that it's over and won't ' happen again, and assures me that our marriage is going to survive. Therefore, this action came not so much as a shock, but as a surprise. Although I consider her actions to be an excellent example of indignity, committed against me, my determination and beliefs caused me to hope that all would work out in the end. .. . . , ;: At'ofe-t; . Ll' ' - :. ' A~ /Ao~ /U'e yeW.? Z #'orzc ' '. 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O/fn-Y' A~ jrfJ'~, L.V/~ /Mt:t~'.pl'f, ~4U'.5. /1 ---, /' ~. -y. ?O/fC". ~ 911tC!S5 .:1/~(f' :? kV1"lSP7,. .', " UI/~L.....2~- <Yfvo/'C!P., rov / -7,. ~c/ ,?fft..:90 . ..z:- ~ ~a~~ v~ )y +~U" ydV ".4// 8/.1" . ,A- 4c>GtJ, A~, .. ydV ,;/ad.4 "9/t:/ofe. NC/'cA.J ~e. .. td.& ~/' 70//(.7 ;n;-..de /~//~ -;/ , ~~ 9'(7-<.) ,,-r/,e sCI/'e J7dU ~~ ~ m@o, ~~ /'C-.-f/ ~5~ Lfe,/ ~ ~o.:0 , t:J7lf? ~//21'" #,/f kP'//' .4tOz" .,J"Y~~' #,/?Je> ,4?~h? / ;'J4>//5<::- k~ as '. 7t' y~/~hJ z 72--~/ ,J"pc/ eA'~h. / ,,4'\ ~0 r~ ci ~l oi:J , ~~~_ rdU y' '^C( ~ ~ l II\. vV'....... ) , ~ ~ '--'I \ \ 1 ~ '~'-'-'"'' -...., ....- ~ . .' ~ .'... . ....' "'~;'''''~'.~'.'':~~~:_.'''':'~._'..:'' '.. ","," -'. .IO~"'.;""_."" " I - fl.' . L....'....-. ....... :"''; ",,,,-.. I , l"\ :\ ~ ~ ....,~~ ~} ~~ /.~~ ~ -" ~ l):) ~ ''{~~ ... -:r - ....... oL.... ~;!">>~- U'(..~2i:r. ~~(.,).... ~::(:\ J .)....;It. -:- ~ , < /.( \I' ;-~~ t: u! ~ ...; -1"Jl.lJ .:..:-~~~ .~. ':) ~O " ~ - ~ ,., ,., - - ~ ::a:: , . LORI J. ATWOOD, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RODGER T. ATWOOD, II, Defendant 95-875 CIVIL TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301ldl OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (~ I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (~ The marriage is not irretrievably broken. Check either (a) or (b): 2. - -},.; "...' (a) I do not wish to make any claims for economic relief. 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. (~I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-affidavit are true and correct. I undertand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: LJ-'-9'!:: ~'1t' (7tu~:W Defen nt NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LORI J. ATWOOD, Plaintiff . . RODGER T. ATWOOD, II, Defendant : 95-875 CIVIL TERM IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE TO: Rodger T. Atwood, II, Defendant You have been sued in an acticn for divorce. You have failed to answer the complaint or file a counteraffidavit to the Plaintiff's affidavit. Therefore, on or before May 19, 1995, the Plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an anBwer with your signature notarized or verified or a counteraffidavit by the above date, the court can enter a f~nal decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 South Hanover street Carlisle, PA 17013 (717) 240-6200 .. TO: FROM: RE: . . The Court of Common Pleas of Cumberland County, Pennsylvania Rodger T. Atwood,II, Defendant Civil Action - Law 95-875 Civil Term May it please the court to accept the following letter as a Counter- Affidavit to an action received by me on 03/06/95 from your Court. I am a layman, and therefore plead for the court's forbearance concerning my knowledge pertaining to the law. I am a Federal Inmate, currently incarcerated at the FCI Allenwood Medium Facility and an therefore at a greater disadvantage in answering a Civil or Criminal action, being unable to avail myself of outside, professional legal assistance. I am presently unable to afford an attorney, nevertheless feel compelled to make at least a feeble attempt to answer the above referenced civil action. The Plaintiff (Lori J. Atwood) and I were married on 3/02/92, with the knowledge that there was a very great possibility that I would shortly receive a Federal Prison Sentence. I was incarcerated on 5/7/92, approximately two months after our marriage. Because I believe strongly in the sanctity of marriage and that it's an act performed before God, I hereby contest this Divorce action and beseech the court to recommend counseling. Enclosed please find a copy of a letter to me from my wife, postmarked Nov. 15, 1994. In this letter she confesses to an adulterous affair, assures me that it's over and won't happen again, and assures me that our marriage is going to survive. Therefore, this action came not so much as a shock, but as a surprise. Although I consider her actions to be an excellent example of indignity, committed against me, my determination and beliefs caused me to hope that all would work out in the end. I would like to take this opportunity to make the court aware . of some of my concerns regarding this action. I have much anticipation regarding a number of arti~les of property that were purchased by me prior to our relationship, and which are now being kept by my wife at her mother's house. We had an understanding that those articles would be returned to me upon my release. I do now, by this letter, lay claim to those articles and request the return of same to my family. I am also presently experiencing a great deal of fear, contemplating what effect this will have on my Rehabilitation Schedule. It has thus far caused me a great deal of stress, mental anguish, and loss of sleep. The few articles alluded to in the above paragraph are all I now possess in this world and have been a source of hope for me in re-building a future. I plead with the court to intervene on my behalf in trying to save this marriage and my few meager items of property. In the event this court determines that this marriage cannot be salvaged, I petition the court to award me monthly alimony payments in the amount of $100.00. ! , , I f I ! I swear that all statements made by me in this letter are true and correct to the best of my knowledge and am aware of the penalties for making false statements to the court. , r , . Your Servant ~..g-q5 ~il~7.P Rodge T. Atwood II .... . .. I . ,f . . At'~e~ 4~/ Aotd ;4;f'c? yoV? 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HQ-c..<.) ~e t..dl= e&e/' yOt'/!y :n- .de ,..I~~/" ;/ &t!' r(?c.) ;9,.e sCI/'e 9C7U ?V~ ~ m@., ..-?...ft /'c-rl/ ~5~ ~Qc'" :z- ~o.0 ~t.o ~//2? ~/f w"// .4az" "..Iry~.,;{) k /?ICJ ~7'~n? / ;P4;'f'S'<::- &'7' as -$ C/~v~/T: ::L 72-~/ J;'fc/ eA'~h / / l\ t," \ L I ll'l, pJ (r~\o ~ ~ jC \~ ,~ e, Xi) ~fiJ YdU ~12/L. ";. . - ... ArR 10 3 34 PHI9S . .., ; ,;.J',fl"'Ofrlct Of. HiE r"CiTliIiH::'7AhY CUHS;::~L~IlO.aO:llHY , 1'~IHlS'(\."f;/il'" ' , i"J -.;;- - ~, ~:~i -:.~ . '" ,"-,' c,;;"). LORI J. ATWOOD, Plaintiff VB. IN THE COURT OF COMMON PLEAS OP CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-875 CIVIL TERM IN DIVORCE RODGER T. ATWOOD, II, Defendant Ar~IDaVIT O~ SBRVICB LORI J. ATWOOD, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . VB. . CIVIL ACTION - LAW . . . RODGER T. ATWOOD, II, . 95-875 CIVIL TERM . Defendant . IN DIVORCE . NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE TO: Rodger T. Atwood, II, Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counteraffidavit to the Plaintiff's affidavit. Therefore, on or before May 19, 1995, the Plaintiff can requeBt the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your Bignature notarized or verified or a counteraffidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 South Hanover Street Carlisle, PA 17013 (717) 240-6200 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-875 CIVIL TERM IN DIVORCE LORI J. ATWOOD, Plaintiff RODGER T. ATWOOD, II, Defendant COUNTER-AFFIDAVIT UNDER SECTION 3301ldl OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree becauBe (Check (i), (ii) or both): (i) The partieB to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claimB for economic relief. I understand that I may lose rightB concerning alimony, division of property, lawyer'B fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's feeB or expenBeB or other important rights. "I verify that the Btatements made in this counter-affidavit are true and correct. I undertand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file thiB counter-affidavit. #' '- '~.- . . , ,,,,~_.,,,,,~..~_~.,<,;..p~,!1:,,,~~~';J,M~ltl1~~,I:~c...~,.~.~},;.,;.., ....... Griffie & Associates ATTORNEYS AND COUNSElORS AT LAW llX) NOMTl1ltANOVlM STMlET C^RllSU. rlNNSYlVANIA 1701.1 t~_:"_",-,,,:~.. ~~ ~_,.~:r="~::':"':-:-:::::J. ~.' ..- . -..... / .-:;;,,'.uIf .," '-. -_.~ ~ . Q-I'LI;,< ~~t;... '~~' ----=-="'-/' CJ ~ i.~ /". : '-tt" ~ ~ - 3 - . 't ,/: t~ :;. 2 = : , ;;"'~'i' . ....;.:.\;..." A . hAlln~fi -' . 51~j)ll~ \J~;' PO~TI',GE : Rodger Atwood 06454-067 F .C.l. Allenwood P.o. Box 2000 Whi te Deer, PA 17887 ~ " . . I , , \ , i ! , .' . . " \ r , r-j. '~, ,- -.- .-- --:-. "'--..-. -. .-...... .--. " #" '-., ~ . . . , ... ,~rlb~:1~.~,~,":~r;',~1{~~it,*~~,VM,7);'1~~5",\ior;~'l}<~,*t,,,,,,c..,,,,.,;.,_,;~*,tl<:~~~~,~~~t~Y1~,~6.~:~~~4~~.~;~'~~.~$?~'~~'!.~!~l~z- Griffie & Associates ATTORNEYS AND COUNSELORS AT LAW lon N()RTII tIANO\'ER STREET CARLISLE. I'[NNSVLVANIA 17011 t..~.._ '........... 2 \~...1"~:;.4~-:::- -J. 9'-~LI~'<";<~l,;"~':~.~":~~~'::~~l : ~ \5 -A: -_ 3 2 -_ !.: ~J" .f> t) rl' .'~ I; -. - I ..i?JJ,:,;""'"' . ".flJ"~<rJl.____~, ; $15c~i,a '~'.l> f'(....~ "'\I~,~,;,. -. Bradley L. Griffi!1_ Esquire GRIFFIE & ASSOCIA'u;:) , 200 North Hanover Street Carlisle, PA 17013 ~ . . . , . , ~ I , , O't'o' - .- -- --:- ~ ....... HIMI6rht:'lI 880 COUNTY Cunberland t. NAME 3 RESIDENCE tFilltJ Rod er St,.., rK R 0 COtIMlIOHWIAUH or "'.....vL\lllUtIA DlMR'MlN' OF ....llK VITAL RICOIIDa DIVORCE 00 RECORD OF OR ANNULMI!NT (CHECK ONE) 0 STATE FILE DATE (1."0 2, DATE tAlon'''' to.y} IN, OF Atwood II BIRTH 1 9 66 c..../y St... ., PlACE IS'.,. 01 FtnIgn Country} Union Count PA OF Carlisle PA BIRTH 7. USUAL OCCUMTION HUSBAND flrfw..} Theodore CII)!, 8oro. tJI lWp Federal Correctional Institute 6 NUMBER I. RACE OF THIS WHITE MARRIAGE 1s t Dll I. MAIDEN NAME 10 RESIDENCE IFIIt'} Lori S',..tOl R,O. 332 North College Street, 12. NUMBER I. RACE OF THIS WHITE MARRIAGE 1s t rn 15. PLACE OF (County) THIS MARRIAGE 17A NUMBER OF CHILDREN THIS MARRIAGE Perr 11B NUMBER OF DEPENDENT CHILDREN UNDER II o Allenwood BLACK OTHER t...."', o 0 WIFE IMiddIe} Ja CII)!, 8<<0. Qt' lWp. Carlisle, e CowI/y Cumberland, BLACK OTHER l$peclfy) o 0 o 1St.,. Of Fcnigrt Country} Penna lvania 111. PLAINTIFF HUSBAND WIFE o [2g OTHER (Spec:ify) N/A OTHER ISpeclfy) o 2f. LEGAL GROUNDS FOR DIVORCE OR ANNULMENT 20 NUMBER OF HUSBAND WIFE SPLIT CUSTODY CHILDREN TO 0 0 0 CUSlOOY OF 22, DATE OF DECREE (Month} (D4y) " SIGNATURE OF TRANSCRIBING CLERK ~I STATE FILE HUMBER Farmer (1."0 ., OATE tAfOnUl) to-y} IN, Clement OF BIRTH 1 19 66 St.,. lI, PlACE (S'." Of FtnIgn Country) PA OF Buffalo, NY BIRTH f4. USUAL OCCUMTIQN lBborer DATEOf' THIS MARRIAGE 19. DECREE GRANTED TO HUSBAND WtFE o [2g 3301(d) 10, I-I 3 (Do'1 17 OTHER '_"I o 23. DATE REPORT SENT IAIon".) 10 VITAL RECORDS (D4,1 r r (ye"} 92 1-/ ..... 8 ~ 8 ~-~~~~~~~~~~~~~-~-~~'~~~~::~~:_~-~~ ~,-- 8 ~ S $ $ ~ ~ ~ ~ ~ .:i " ~ ,,' ~ ,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ,,~ ~ PENNA. ,', * ~ " ~ 8 . 3 ~ ~ ,', Pol ~ ~ ~ (-. ~ g ;; ~ ~ 8 ~ ~ ~ i ~.' ~ <:" a ',' ~ ". ~ ., w ',' ~ ',' ;i ',' ~ ',' ~ .~ ~ .' i~ Allest: J, ,.. ~ I~ ~ IV ~ I," ~ Prothonotary \;. ~-----,. -~ ---.-,-."..---"....' ,..' ..,,,--,.........,..,.." , ~~ ~_~~~~~~*_~~*~*-*-**_ro.~~ro~-*~- lDRI J. A'lWOOD ..'..,..,....,......,..'.... ",....,2.., ,',',',',",',"',' ~ il d ........... :! N (), ,....~~:,~7.~,...., ~JY.J;b...., 19 95 , ' ,..Plaintiff VCI'SIIS t ~.' RODGER T. A'lWOOD II . ..............-......-. ... ....,..- ...,..... .! :1 :' ;; w ',' , Defendant ~ ',' i ',' DECREE IN DIVORCE i ',' t ',' i ',' ~ ~ 8 ~ ~ ~ i ',' AND NOW, ' ,.,TI,l~~, .. .. .. .. .. , .... .. ' .. '. 1 ~~ .. .., It Is ordered and decreed that""", ,l,.QJ;i,J. ,ft.,twoQd"""""""""""""" plaintiff, and"", ~~~~, "!.., ~~~?~'" ~~"""""""""""""""',. defendant, are divorced from the bonds of matrimony. .:i ~ 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; s ~ ,,' t ',' ", ,~o.l'\~ " "".' " ,," ,," ,.', " " " " , , " ,'" ,. ,.' "".",. ,,",' ,..".,., ,;, ~ .0.0.0.....0 ...... '...0 .... '0 ........ .., ,.. .... ,0 ....... ......... "0 ...... ~ ~ ~ ,,' Oy The Court: LORI J. AlWOOD, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. RODGER T. AlWOOD, II DEFENDANT 95-0875 CIVIL TERM IN DIVORCE ORDER OF COURT AND NOW, this 28th day of June, 1995, the praecipe for the entry of a final decree In divorce at this time, IS DENIED. Defendant opposes the entry of the divorce. He claims economic relief. Bradley L. Griffie, Esquire For Plaintiff No petition for bifurcation has been filed. By the cdG,(, , /{ ; V~~ Edgar B. BaYI~ J. Rodger T, Atwood, II, Pro se 06454-067 LCI Allenwood P.O. Box 2000 White Deer, PA 17887 _ ~ ~("'/~9Iqs. ,,!,1'. :saa , , ."/<Cr'I.:"':"';., ~!1 !.' t!I'," _"';j;j'J ,~r,I,~,' ,:u :; ,il~ ; I, 56. HPt" 6Z NOr ..,.. ...,. - ,"' ~. .r ., ~~~ .~. . '..- ::- '" U'1 ~ ,0-<0': ,-<:> ~"'-.,J ,.' => -, .-. , ~ .-, .. (9 ;~ ~~ l:J ti .. 0 P<~ .., ... ~~ ~ J I! f'I ... ~ ~~ ... - u~tIl0 I! < ~ ~Q o,ffi~ ... tIl Q. .... ~ ~ ~ < !~~~ ..... ....... g z ' ..... fl ~~ l! Z Q. ... <i ~ ." ... W III W ..::E :J .., z :J: oJ _ GI 0"';3 :J :t VI ;~ a: ::t !!! tIl Ii a: !;~h ~P< . hi g Ii ;i o Ii! !!) ii: < 06 Z J: I&. Z " <( <c . - 8 _ :t H ~~ a: N u . ..., ffi ~~ C> ~~~~~ .... ~ 9 , ....Ml".. '0."4..". r'''.'A nus ~....,.o:tA~"""l'IIU'-"'" .. J J, ~').. ~'1 r- - \10 .1 4 s:: ~ ' I t I' ".;. 56. ,,:' 1]:; 8 ~nv LORI J. ATWOOD, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RODGER T. ATWOOD, II, Defendant 95-0875 CIVIL TERM IN DIVORCE PETITION POR BI~URCATION AND ENTRY O~ DECRBE IN DIVORCE AND NOW, comes Petitioner, Lori J. AtWOOd, by and through her counsel of record, Bradley L. Griffie, Esquire, and petitionB the Court aB folloWB: 1. Your Petitioner is the above named Plaintiff, Lori J. AtWOOd, an adult individual currently residing at 332 North College street, CarliBle, Cumberland County, pennBylvania. 2. Your Respondent is the above named Defendant, Rodger T. Atwood, II, an adult individual currently incarcerated at the Federal Correctional InBtitution, Allenwood, Post Office Box 2000, White Deer, Union County, Pennsylvania. 3. The Petitioner filed a Complaint in Divorce on February 17, 1995, alleging the parties' marriage is irretrievably broken and, therefore, the parties should be entitled to a divorce pursuant to section 3301(d) of the Domestic Relations Code; that the parties have lived separate and apart since May 2, 1992 and, therefore, Petitioner is entitled to a divorce purBuant to Section 3301(d) of the Divorce Code of 1980 as amended; and that the Respondent has committed such indignities upon the person of ~ the Petitioner, who iB the innocent and injured spouse, aB to make her condition intolerable and life burdensome, thUB, allowing a divorce to be entered pursuant to section 3301(a) (6) of the DomeBtic RelationB Code. 4. Your Petitioner served a certified copy of the Complaint in Divorce, a copy of the Petitioner's Affidavit Pursuant to Section 3301 (d), a Notice of Intention to Request Decree in Divorce and a Section 3301(d) Counter-Affidavit upon the Respondent at his present residence in the Federal Correction Institution at Allenwood. 5. Respondent prepared, signed and forwarded to the prothonotary's Office of Cumberland County the Section 3301 (d) counter-Affidavit, but did not provide a copy to Petitioner or counsel for Petitioner. 6. Petitioner filed a Praecipe to Transmit the Record to finalize the divorce pursuant to section 3301(d) which was denied when the record reflected that the Respondent's 3301(d) Counter- Affidavit had been filed. 7. The parties married approximately one and one-half months prior to Respondent's incarceration in the Federal Correction Institution at Allenwood. 8. The parties have no marital assets. 9. The filing of Respondent's counter-Affidavit was done solely to delay the finalization of the divorce as there are no economic issues to resolve in this case. 10. Contemporaneously with the filing of this petition for Bifurcation, petitioner haB filed a Petition for Leave of Court to file an Amended Complaint in Divorce to raise the fact that the ReBpondent has been sentenced to imprisonment for a term of two or more yearB upon conviction of having committed a crime, thUB, providing the Petitioner with groundB for divorce pursuant to Section 3301(a) (5) of the Domestic Relations Code. 11. Petitioner has had no relationship with the Respondent of any nature whatsoever for well in excess of three yearB and wishes to move on with her life. 12. The Petitioner has expended great sums in COBtS, both for the filing and initiation of thiB divorce action and COBtB for service of the Respondent at his place of imprisonment in Union county, PennBylvania, and, therefore, respectfully requests that the Court authorize service by first class mail, postage prepaid upon the Respondent. WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon the Respondent to show cause, if any he has, aB to why this case should not be bifurcated and why the Court should not enter a Decree in Divorce pursuant to Section 3301(d), 3301(a)(5), or 3301(a) (6) of the Domestic Relations Code. Respectfully submitted, riffie, Esquire ey'etitioner North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the BtatementB made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penaltieB of 18 Pa.C.S. section 4904, relating to unBworn falsification to authorities. OAT"' 7(Z!7'- ~TWOO~/ ~ ~ ~;: r ~1. - .' ,;: , ~, 0- , " -'1 - ~ ':J ('0 '- q. c-J ,>' '1 r-J .... ,.. \/l <:1:: ~ ~ 1 F ~~ ~~ ~~ zffi !i~ ~~h ~~9Q ~8lSl~ ~~ ~~~ Ul - ~~~~ ~: ~-~ i~!~~ ~~~~~ ~~~~~ UI \II .. I- .. < ~ _ . .. P1 U j III 0 o I ffi"" U) ... > - (1)10< < .. z.. 1;; C , oW Z X ~ IoU II::Z:" lIJ 0 ~ :i _ ~ 0 .. II. < Z ~ !!: 8 a: N Cl - .... ....-} ~~ .... .... .... f~ ~~ . H ~ ffi ~, . .., ~ . . . - .. 0 .. N .. ... .. - .. 011I< III Z .. U1 - Ii .. C .. ..:I! " - '" .. " .. .. Ill.. .. 0" z .. ., ~ - '" u " ('ED? r-'lQCir ' .,) I .... \) ;;;;J .f . . . . LORI J. ATWOOD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 95-0875 CIVIL TERM vs. RODGER T. ATWOOD, II, Defendant IN DIVORCE WRIT O~ HABBAS CORPUS TO J.D. SWINSON. WARDBN. ~BDBRAL CORRBCTION INSTITUTB. MBDIUM SBCURITY. AT ALLBNWOOD WHITE DBER. PENNSYLVANIA Greetings: We command you that the body of Rodger T. Atwood, II, under your custody detained, as it is said, by whatsoever name he may be detained, you bring before the Honorable Edgar B. Bayley, Judge of our Court of Common Pleas in the County the Courthouse in Courtroom number 2 on Monday, of Cumberland at .:<3 I/o{ the J.6'th day of October, 1995, at 1:30 p.m. to do, submit to and receive whatever our Judge shall then and there consider relative to the hearing previously scheduled in this matter. Witness, the Honorable Edgar B. Bayley, Judge of our said court, this .;2fc1i--- day of September, 1995. ~...Lii Q. -e~#Um ~ Lawrence elker, prot ono a y LORI J. ATWOOD, Plaintiff : IN ~HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AND NOW, this 26 day of September, 1995, upon . . VS. : 95-0875 CIVIL TERM . . RODGER T. ATWOOD, II, Defendant : IN DIVORCE . . ORDER OF COURT consideration of the within Petition and upon the Motion of Bradley L. Griffie, Esquire, Attorney for the above named Plaintiff, IT IS ORDERED AND DIRECTED that a Writ of HabeaB Corpus Ad Subjiciendun be issued forthwith and that the above named Defendant be brought to the Court of Common Pleas of Cumberland County, Carlisle, Pennsylvania, for a hearing ,:(3 presently scheduled for Monday, October ~, 1995 at 1:30 p.m. in Courtroom Number 2 of the aforesaid Courthouse. IT IS FURTHER ORDERED AND DIRECTED that the Prothonotary of Cumberland County, Pennsylvania, serve the Warden of the Federal Correctional Institute at Allenwood, White Deer, Union County, Pennsylvania, with said Writ or a copy thereof.~ BY THE COU ) , , LORI J. ATWOOD, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 95-0875 CIVIL TERM IN DIVORCE RODGER T. ATWOOD, II, Defendant PETITION ~OR WRIT OF HABEAS CORPUS TO THE HONORABLE THE JUDGES OF SAID COURT: Petitioner, Bradley L. Griffie, Esquire, attornsy of record for the above named Plaintiff, respectfully represents as follows: 1. The above named Plaintiff initiated a Complaint in Divorce against the above named Defendant fo~ various reasons, all of which were set forth in the Complaint in Divorce and Amended Complaint in Divorce in this action. 2. The above named Defendant is incarcerated in the Federal Correctional Institute at Allenwood, where he has been so incarcerated for in excess of two years and where he is expected to be incarcerated for several additional years at a minimum. 3. The Plaintiff attempted to finalize a divorce in this case pursuant to Section 3301(d) of the Domestic Relations Code, as the Defendant refused to cooperate relative to the finalization of the divorce pursuant to Section 3301(c) of the Domestic Relations Code. 4. Without providing Plaintiff or her counsel with a copy, the Defendant forwarded a signed Counter-Affidavit Under Section 3301(d) to the prothonotary's Office in Cumberland County. 5. The filing of the Counter-Affidavit Under Section 3301(d) resulted in the inability of the Plaintiff to finalize the divorce. 6. There are no marital property or economic iSBues to be advanced by the Defendant, as the parties were only married for a few days prior to Defendant's incarceration. 7. The sole purpose for the Defendant filing a Counter- Affidavit was to stall the ultimate finalization of the divorce in this case. 8. The Plaintiff has filed a Petition for Bifurcation so that she can conclude her divorce and allow the Defendant to pursue economic issues if he believes they exist. 9. The Plaintiff has filed a Petition for Bifurcation for the entry of a Decree in Divorce which has caused a hearing to be scheduled for Monday, octoberU, 1995 at 1:30 p.m. in Courtroom number 2 of the Cumberland county Courthouse in Carlisle, Pennsylvania, in front of the Honorable Edgar B. Bayley. 10. To date, neither the Plaintiff nor her legal counsel have received any response from the Defendant as to whether he will cooperate in the finalization of this divorce, whether he intends to appear at the hearing, or whether he intends to defend against the bifurcation issue. 11. In order to avoid the complications that would result in the failure of the Defendant to appear at the hearing on ;!3 October l6, 1995, Plaintiff believes it is necessary to order the Defendant to be present at that hearing. I verify that the statementB made in the foregoing document are true and correct. I understand that false statementB herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: 91:)(/5, I ( / l;~ ...~ LM t::- CT) - - :..:;", ~ -t " en .. ., ~ = c:..:') \'--...1 -, ;~ ~ ~." ~ = -') @ ~ ~;:!i ~~ E~ gj ti ti 0 I- W I ~ ~ ~ ~ W ~ - gQ g ~ ~ g ~ < !~~~ ..... 1-1.... ~~ ~ 1 ~ ~ ,., Ul Q. g Z ' ..... iJ - " .~ ., z < II: .... :1 ti < W ~ :f i -,~ 16 z I: ... " J: ., a: :t !:! Ul Ii: II: ~~ ~~ !!! g S g o ~ ~~~~~ "'<z6 z x . ~ 8 or 0( ~ ~ . _ J: U <~~ Eo< 19[;3 0: N . t!) .., ~ ~~!S~~ 1-1 ~~ ~ ~ U011-1 _...,.. .oc.u...,.nu..... nll._ OHftWO.I 00"'''''' 1\OOn In'U.nw . . IJUL ;J, , ' !' LORI J. ATWOOD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. RODGER T. ATWOOD, II, Defendant 95-0875 CIVIL TERM IN DIVORCE AND NOW, thiB 7-ft-. ORDBR @OR'5-- day of ~ 1995, upon presentation and consideration of the within Petition, the Petitioner iB granted leave to file an Amended Complaint in Divorce to include Section 3301(a)(5) as a grounds for divorce in her Complaint in Divorce and to request payment of Respondent. counsel fees and expenB~B I , / / BYC;;~ Edgar B. Bayley t J by the I' '. , ~11i;' . :." 56. \iI' I1ti 6 L ~nv vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-0875 CIVIL TERM IN DIVORCE LORI J. ATWOOD, Plaintiff RODGER T. ATWOOD, II, Defendant PETITION ~OR RELIEP TO ~ILE AMENDED COMPLAINT IN DIVORCE AND NOW, comes Petitioner, Lori J. Atwood, by and through her counsel of record, Bradley L. Griffie, Esquire, and petitions the Court as follows: 1. Your Petitioner is the above named Plaintiff, Lori J. Atwood, an adult individual currently residing at 332 North College Street, CarliSle, Cumberland County, Pennsylvania. 2. Your Respondent iB the above named Defendant, Rodger T. AtWOOd, II, an adult individual currently incarcerated at the Federal Correctional Institution, Allenwood, Post Office Box 2000, White Deer, Union county, PennBylvania. 3. Petitioner filed a Complaint in Divorce in this action on February 17, 1995 requesting a divorce based upon consent (Section 3301 (c) ), two year sep..ration (Section 3301 (d) ), and indignities (Section 3301(a) (6)). 4. The parties have not had any relationship of any nature whatsoever since the Respondent's incarceration in May of 1992. ~ 5. The Petitioner fully expected the Respondent to cooperate as the parties were only married for approximately one and one-half months before Respondent's incarceration at the Federal Institution and the parties have no marital assets. 6. The Petitioner fully expected the Respondent's cooperation in finalizing the divorce. 7. Despite this, the Respondent has now filed a Counter- Affidavit under Section 3301(d), thus, delaying the finalization of the divorce in this matter. 8. Your Petitioner, contemporaneously with filing this petition, is filing a Petition for Bifurcation so that the Court can bifurcate this matter and enter a Decree in Divorce purBuant to the request of the Petitioner. 9. The parties do not have marital assets of any kind to distribute and there are no financial or economic issues involved in this case. 10. The filing of the Defendant's counter-Affidavit pursuant to section 3301 (d) was done solely to cause the Petitioner additional costs and to delay the entry of a Decree in Divorce in this case. 11. The Petitioner does not have funds to pay for the costs and fees associated with these additional actions necessitated by the baseless actions of the Respondent. . 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. Sectlon 4904, relating to unsworn falsification to authorities. /J X~ '~ ~~ LO~I J. ATWOOo/ DATE: 7/.)' ,c,.~' I .-'") ~r, .0. ~ 0.::: " ~ .., u..~ ~ " ~ ~f j'., e"J n, - '- c2; 1 ~ R V) ~ , ~ < . 0 ~ I-J I-t ..:l 0 Po O..:l~ < Ul E-I<:E I-t III .. Z I>: OZ ~ w 0 ~ ~ Ul~ g< w ti 2 ~~ I-t oo~ > IE I-t Po~E-I~..:l 0 ~ .. 1'1 w " oz I>:t&.oz>o 0 ,j UI(; I! ~ uo .... ~.a.J 0 E-I~Ul .f5" o III ~ 0 .... oc U I-t..:lZ Ul .. > ~ on z . t&.U ~'ooi Onl ZE-I..:lZ Ul '10< on - " 0 0.a.J O'tl Ul~Ul<~ c( " ~ .. .. .. IE C OC ~c <oz Po ,. % .. ..:E::J E-IZ< 0.... E-ICIl ~I>:I-tE-l ItS z ... :; i!: .. I>:<I-t ~nl . <.... lll< < IE i!: " III IE:! III ~ IE :J OW ::>..:lZ E-I..-t Ul CIl :a~Z I>: z .. 01>:< <Po > '0 o ~ ii: dB .. ~ U~> E-I 1-t>O~ IL lll..:l . t&.ZE-IE-IO 8 ~ :c ~:E>O I-J Cl OOUI-t ii: N U :I:OUl Ul~~~ C> E-IUZ I-t Cl E-IZI>: E-I Z I>: 0 I-tI-tI>:UI-t zt&.~ 8 0 ~~O~[i HOPo I>: UlUUl , , '.~ . - . OCT 1 3 \9S5Ib~ LORI J. ATWOOD. Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA 95-0875 CIVIL TERM RODGER T. ATWOOD. II, Defendant IN DIVORCE warT OP HABEAS CORPUS TO J.D. swrNSON. WARDEN. PEDBRAL CORRBCTrON rNSTITUTB. MEDIUM SECURITY. AT ALLBNWOOD WHITB DEBR. PBNNSYLVANIA Greetings: We command you that the body of Rodger T. Atwood, II. under your custody detained, as it is said, by whatsoever name he may be detained, you bring before the Honorable Edgar B. Bayley, Judge of our Court of Common Pleas in the County of Cumberland at Fourth Floor, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, in Courtroom number 2 on Monday. the 23rd day of October, 1995, at 1:30 p.m. to do, submit to and receive whatever our Judge shall then and there consider relative to the hearing previously scheduled in this matter. This matter is a contested divorce proceeding necessitating the presence of the said Rodger T. Atwood, II. This Writ is issued at the request of the above-named Plaintiff, Lori T. Atwood, and her legal counsel. As the aforesaid Rodger T. Atwood, II, has made certain defenses and claims by Af;fidavit in the divorce action pending against him, his presence is now required to give testimony under oath as regards those defenses and claims. The inmate's ongoing incarceration essentially creates the impossibility of resolving this case through any means other than via his presence at the scheduled hearing. The said Rodger T. Atwood, II will be incarcerated at the holding cell of the Sheriff's Department, Cumberland County Courthouse, Carlisle, Pennsylvania, during these proceedings. If it is necessary to detain him for a period requiring an overnight stay, he will be detained at the Cumberland County Prison, Claremont Road, Carlisle, Pennsylvania. The Cumberland county Sheriff's Department is the agency responsible for transporting the said Rodger T. Atwood, II from the Federal correction Institute at Allenwood to the Court of Common Pleas of Cumberland county, carlisle, Pennsylvania. Information relative to the specific individual transporting the said Rodger T. Atwood, II at the direction of the Court is listed below. The projected date of return of the inmate is Monday, October 23, 1995. I; ~ -rJ . ~r._<.tiP a. . I '" < ".-0 t\ ~ Lawrenc Welker, Proth n ary Cumberland county Courthouse Carlisle, PA 17013 (717) 240-6195 <9-t:t.. I~. l'i%"' This is to certify that the above-named inmate will be provided safekeeping, custody and care while in the custody of the Cumberland County Sheriff's Office and that the said Cumberland County Sheriff's Office will full assunle responsibility for that custody, to include providing the inmate the level of security required by the Bureau of Prisons pOlicy, and will return the inmate on the conclusion of the inmate's LORI J. ATWOOD, Plaintiff . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : 95-0875 CIVIL TERM RODGER T. ATWOOD, II, Defendant : IN DIVORCE ORDER OF COURT AND NOW, this It day of October, 1995, upon presentation and consideration of the within Petition and upon the Motion of Bradley L. Griffie, Esquire, attorney for the above-named Plaintiff, IT IS ORDERED AND DIRECTED that the attached Writ of Habeas corpus Ad Subj iciendun be issued forthwith and that the above-named Defendant be brought to the Court of Common Pleas of Cumberland county, Carlisle, Pennsylvania for a hearing presently scheduled for Monday, October 23, 1995, at 1:30 p.m. in Courtroom Number 2, of the Cumberland County Courthouse, Carlisle, Pennsylvania. IT IS FURTHER ORDERED AND DIRECTED that the Prothonotary of Cumberland County, Pennsylvania, serve the Warden, issue the Writ, and forward it to the Cumberland county Sheriff'S Department for that Department's execution and service of the Writ upon the Warden of the Federal Correction Institute of Allenwood, White Deer, Union county, pennsylvani;. I BY THE c6URT, ~t.!.,. .- Judge LORI J. ATWOOD, I IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . 95-0875 CIVIL TERM . . . RODGER T. ATWOOD, II, . IN DIVORCE . Defendant I WRI~ O. BABBAS CORPUS TO J.D. SWINSON. WARDEN. FEDERAL CORRECTION INSTITUTB. MEDIUM SECURITY. AT ALLENWOOD WRITB DEER. PENNSYLVANIA Greetinqs: We command you that the body of Rodqer T. Atwood, II, under your custody detained, as it is said, by whatsoever name he may be detained, you brinq before the Honorable Edgar B. Bayley, Judqe of our Court of Common Pleas in the County the Courthouse in Courtroom number 2 on Monday, of cumberland at ~ ~ n.cL the 1-61:11 day of October, 1995, at 1:30 p.m. to do, submit to and receive whatever our JUdge shall then and there consider relative to the hearing previously scheduled in this matter. Witness, the Honorable Edgar B. Bayley, Judge of our said Court, this ~~:tA. day of September, 1995. ~":'l..~ a. . -p ~c..J .DF.\ Lawrence elker, protnonotary TRUE COpy FROM RECORD In T :~I nl'~'1 :. r. "I, i h.~r~ ~~Io s~t my hand'" and flu s.:a: ci ;~:d CJJrl at Carlisle, Pa. This ~d:fi:. d~y of~..::! 199..f.:. o,.n 'L. i'~R." , .................~1...~..~... ... '", ...n..._oo._ .efi1;t , Prothonotary - EXHIBIT "A" - , , vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 95-0875 CIVIL TERM IN DIVORCE LORI J. ATWOOD, plaintiff RODGER T. ATWOOD, II, Defendant ORDER 01' COURT AND NOW, this .;1(" day of September, 1995, upon consideration of the within Petition and upon the Motion of Bradley L. Griffie, Esquire, Attorney for the above named Plaintiff, IT IS ORDERED AND DIRECTED that a Writ of Habeas Corpus Ad Subjiciendun be issued forthwith and that the above named Defendant be brought to the Court of Common Pleas of Cumberland County, Carlisle, Pennsylvania, for a hearinq .23 presently scheduled for Monday, October ~, 1995 at 1:30 p.m. in Courtroom Number 2 of the aforesaid Courthouse. IT IS FURTHER ORDERED AND DIRECTED that the prothonotary of CUmberland County, Pennsylvania, serve the Warden of the Federal Correctional Institute at Allenwood, White Deer, Union County, Pennsylvania, with said Writ or a copy thereof. BY THE COURT, I~I fu~'~ Edgar B. ayley, Ju e T:'l'" I. . . j:l Tc.;lim~: ." ' . .. .:/ hJnd ,:~d the SE~i 0; S;J!,j CCJd Ji ':'::I:~I'~' Pa. ihis H"!?'f?~.. day of......~~,.;!..;, 19_~ ................~...4.~:f~ oCl~"'rolhonotary . '. vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 95-0875 CIVIL TERM IN DIVORCE LORI J. ATWOOD, Plaintiff RODGER T. ATWOOD, II, Defendant PETITION FOR WRIT OP HABBAS CORPUS TO THE HONORABLE THE JUDGES OF SAID COURT: Petitioner, Bradley L. Griffie, Esquire, attorney of record for the above named Plaintiff, respectfully represents as follows: 1. The above named Plaintiff initiated a Complaint in Divorce aqainst the above named Defendant fo;r: various reasons, all of which were set forth in the Complaint in Divorce and Amended Complaint in Divorce in this action. 2. The above named Defendant is incarcerated in the Federal Correctional Institute at Allenwood, where he has been so incarcerated for in excess of two years and wher~ he is eXPected to be incarcerated for several additional years at a minimum. 3. The Plaintiff attempted to finalize a divorce in this case pursuant to Section 3301(d) of the Domestic Relations Code, as the Defendant refused to cooperate relative to the finalization of the divorce pursuant to Section 3301(c) of the Domestic Relations Code. 4. without providing Plaintiff or her counsel with a copy, the Defendant forwarded a signed Counter-Affidavit Under Section 3301(d) to the Prothonotary's Office in Cumberland County. 5. The filing of the counter-Affidavit Under section 330l(d) resulted in the inability of the plaintiff to finalize the divorce. 6. There are no marital property or economic issues to be advanced by the Defendant, as the parties were only married for a few days prior to Defendant's incarceration. 7. The sole purpose for the Defendant filinq a Counter- Affidavit was to stall the ultimate finalization of the divorce in this case. 8. The Plaintiff has filed a Petition for Bifurcation so that she can conclude her divorce and allow the Defendant to pursue economic issues if he believes they exist. 9. The Plaintiff has filed a Petition for Bifurcation for the entry of a Decree in Divorce which has caused a hearing to be scheduled for Monday, October 16, 1995 at 1:30 p.m. in Courtroom number 2 of the Cumberland County Courthouse in Carl isle, Pennsylvania, in front of the Honorable Edgar B. Bayley. 10. To date, neither the plaintiff nor her legal counsel have received any response from the Defendant as to whether he will cooperate in the finalization of this divorce, whether he intends to appear at the hearing, or whether he intends to defend against the bifurcation issue. 11. In order to avoid the complications that would result in the failure of the Defendant to appear at the hearinq on October 16, 1995, Plaintiff believes it is necessary to order the Defendant to be present at that hearinq. 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. Section 4904, relatinq to unsworn falsification to authorities. DATE: 1b'/$r- I f 8AAoLlV L. GRI"II McI1Iu.1 R. CALVlAT GRIFFIE & ASSOCIATES ATTORNEYS AND COUNSELORS AT LAW 200 NOflTM H."""". STO'IT C."".... PA 17013 (717) 243-5551 1 (800) 34 7.5552 FAX 717-243.5063 T""", L. e.uu. ucw. AIIIIUNT Roo.. J. GoOHOlVf o.'ICI MANA"". c.........._ T.UIl Iluou>"" SuIT. 5110, 14 Nom.. MA" STOUT e..........u.... PA 17201 (717) 257.13110 October 12, 1995 RIOlo' 1'0: e....1lI ROdger ~, AtwOOd, II 06454-067 FCI Allenwood P.O. Box 2000 White Deer, PA 17887 Dear Mr. Atwood: Although I understand you have already received a copy of the Court's Order in this case. I am enclosing a photocopy of that Order for your records. In addition, I am providing you with a copy of two documents. One is an Affidavit of Consent in which you would consent to the divorce in this case. The second is . a Praecipe withdrawing your claim for economic relief. As you have been aware from the time this action was initiated, there is no economic relief to be gained in this case. There is no property as all the property was confiscated through your criminal proceedings. There is no claim for any type of payment of any nature from Ms. Atwood to you. The purpose in filing your documentation, as is now becoming obvious, was to delay these proceedings. Under any circumstances, as you are aware the Court is going to require you to be in attendance at the hearing on October 23. The Court has denied your Petition requesting to be exempted from the writ of habeas corpus. Therefore, we plan to see you in court at that time. If you wish to eliminate these ongoing proceedings, please sign, date and return the Affidavit of Consent and the Praceipe that I have enclosed. I have enclosed a self-addressed stamped envelope for purposes of having you return these documents to me. If they are received well in advance of the October 23, 1995 hearing, we can conclude this case without the necessity of a hear irlY . In addition, attorney's fees in position to require believe that your I remind you that we have made a claim for this case. While the court may not be in a any sort of payment from you at this time, we actions in this case in making claims for October 14, 1995 Griffie 6 Associates Attorneys and Counselors at Lav 200 North Hanover Street Carlisle, Pa. 17013 Dear Mr. Griffie, Apparently you have not comprehended or have aisunderstood a nuaber of points regarding ay position in these divorce proceedings. It is not, nor has it ever been ay intent to delay these proceedings in any way, but rather to obtain written assurance either from the court or your office, that a member of ay faai1y would be peraitted to retrieve my personal effects that have been utored at the residence of Plaintiffs' Mother since the Spring of 1992. With an unlearned band, I subaitted (3) three petitions to the court on October 2nd, 1995. I have received reply on (1) one of those petitions, requesting exeaption on the Writ of Habeas Cprpus. The second petition sought the written assurance referred to in the second parsgraph above. The third petition asked the court to allow me to withdraw ay counter- Affidavit and to accept another one attached to that petition, wherein I do consent to the divorce and do not seek economic relief. The bottom line Hr. Griffie ing the retrieval of ay "stuff". be seen as junk, but it is all I is that I seek only written assurance regard- When viewed by the world, ay "stuff" would possess in this world. Although the esteem I afforded you was greatly diminished by the next to last paragraph in your most recent letter to me, I now rely and call upon whatever integrity you possess to obtain written assurance in my interest. Lori has not given me any indication that there is or would be any problea in retrieving said property, I just want to avoid any potential hassle in my Brother Jaaie picking those things up. I spoke with Plaintiffs' sister, one Barbara Baker, on Friday 10/13/95, at which time she informed me that there was no problem in picking up my belongings. If you'll have the court grant my petition regarding my belongings, or give me written assurance yourself, I'll gladly send you the two forms you requested. If not. then I'll see you on Monday the 23rd. You cannot expect me to inadvertant1y waive ay rights to my junk by signing your foraa. In addition, I do object to you introducing my Federal sentencing record, for it has no bearing on this proceeding. If the character of Defendant and Plaintiff were compared by criminal records. I'd probably win nut. -:r'l':"!':'ll,. Sincerely, Rodger T. Atwood II ~ '7: /7ih.~:zr ef dant '- . . . Rodger T. Atwood II lCI Allenvood P. O. Bos: 2000 White Deer, Pa. 17887 06454-067 Unit 4& ~ - -' - - - - ---....... -- -- - .-'" .~. ~ 155413 10/16/95 Court of eo-,n Pleas of CUllberland County Pennsylvania Judge Edgar Bayley c/o Office of Prothonotary Cumberland County Courthouse South Hanover Street Carlisle, PeDDsy1vania 17013 "LEGAL MAIL" 1,"111,"111",,"11.,11,1..1.1 '",11"11",11,,,11.;,1.1..1,',11.,1 .""ill~" zw"-'=<"~.vit-~--T .'_'H__ ,,<" . . ." '. . .' t ,. , .~.... .. - . -: . .'..- . . .-.- - . . _..........IJ rt:UI::RAL CORRECTIONAL INSTlruTIOtll w.."-n": r'...-..... n, ..-...,... ........, :---'Ocrt4 1995 THl.'C SFE~' YC~'. INS;:~' PRO: ~ JUR::: II./.T:::. r -~~'-I:~.l ".'.".; : ~IGH "', TO l.'~ _: ;~;10CEDUF1:::': ~ ::~ EM I::EE111;:::: .... :.. T~::: ~~:RITEn Fl.":::::., -: \'.'~ ::'::-1 THIS j.',\':' eLf':::;;,: .',: :-'.-.Y\"J!::I.i-\,:. . ;.~.1 [:.~'2~._~.:.: :~ \":i);'-;-::1 :~:::-~. C(:~'.:~.:-~ . 2' :~....: ::..: ; ,J:I FO?r.V.~;:Dl::....; iV ,t,;';,:)THER A:Ci:.:.;:;:r;;, PlC;.:;e R",TURN rHf GNCLOSUili:: ro IH~ t.!JOVli ADDRESS. .J r--_.. / , -~'-""'-'''''''''l\~'''~~W4'''''i_' "V" ''"tX~:'''7~~ , .-- . . " . , " - . -... ~ .. -r., 1rr:r ~ LORI J. ATWOOD Plaintiff : IN THE COURT OF COMMON PLXAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . VD. : CIVIL ACTION - LAW . . RODGER T. A'lWooD, II Defendant : 95-0875 CIVIL TERM : IN DIVORCE PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS AND NOW, comes Petitioner, Rodger T. Atwood II, pro se, and petitions the court as follows: 1. Your Petitioner is the above named Defendant, Rodger T. Atwood II, an adult individual currently incarcerated at the Federal Correctional Institution, Allenvood, Post Office Box 2000, White Deer, Union County, Pennsylvania. 2. Petitioner respectfully requests your Honorable Court to issue an Order granting Petitioner Leave To Proceed IN FORMA PAUPERIS, according to rule 1920.62 (Proceedings by Indigent Parties) (effective 07/01/95) per Rule 240 IN FORMA PAUPERIS. . LORI J. ATWOOD IN THE COURT OF COMMON PLEAS OF ",. Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . CIVIL ACTION - LAW . RODGER T. ATWOOD II . 95-0875 CIVIL TERM . Defendant . IN DIVORCE . AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the Defendant in the above .matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: Rodger T. Atwood II Address: FCI Allenwood 06454-067 P. O. Box 2000 White Deer, Pa. 17887 Social Security Number: 199-62-5260 (b) Employment Employer: Federal Bureau Of Prisons FCI Allenwood P. O. Box 2000 White Deer, Pa. 17887 Salary or wages per month: $ 5.25 Type of work: Orderly (c) Other income within the past twelve months Other: $ 200.00 (gifts from family) (d) Other contributions to household support NONE ...... ..... (e) Property owned NONE (f) Debts and obliRations Other: $ 25.00 (Federal Court Aaessment) (g) Persons dependant upon you for support Children, if any: Name: Rodger T. Atwood III Age: 8 yrs. 109 Mountainview Drive Mount Holly Springs, PA. 17065 4. 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalities of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. DATE: /D-/.;1.-95 ~ T. /J;&;-~7l: Petitioner " - <= ~ . :,-1" ...~ ::. ~.' ;'1; ~;:'., ~.l ~~ -~? ~ t.~-;! :;~ C": N IN -0 :0:: - c..c c.n . .- . - LORI J. ATWOOD : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA vs. . CIVIL ACTION - LAW . : RODGER T. ATWOOD II 95-0875 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the Defendant in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: Rodger T. Atwood II Address: FCI Allenwood 06454-067 P. O. Box 2000 White Deer, Pa. 17887 Social Security Number: 199-62-5260 (b) Employment Employer: Federal Bureau Of Prisons FCI Allenwood P. O. Box 2000 White Deer. Pa. 17887 Salary or wages per month: $ 5.25 Type of work: Orderly (c) Other income within the past twelve months Other: $ 200.00 (gifts from family) (d) Other contributions to household support NONE . .-.......-.- ~.....-.... '- J (e) Property owned NONE (f) Debts and obligations Other: $ 25.00 (Federal Court Asessment) (g) Persons dependant upon you for support Children, if any: Name: Rodger T. Atwood III Age: 8 yrs. 109 Mountainview Drive Mount Holly Springs, PA. 17065 4. I understand that I have a continuing obligation to inform the court of improvement in m:l financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalities of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. DATE: It> - /.;2 - 95 ~ T 11ti;~:r+; Petit one~ IN THE COURT OF COMMON PLEM OF CUMBERLAND COUNTY, PENNSYLVANIA LORI J. ATWOOD, Plaintiff VS. RODGER T. ATWOOD, II, Defendant PETITION FOR A CONTINUANCE GRIFFIE & ASSOCIATES ATTORNEYS'AT'LAW 200 NORTH HANOVER STREET .. CARLISLE. PA 17013 . SUITE 550 14 NORTH MAIN STREET CHAMBERIBURG. PA 17201 Ocr 19 Lj 23 PH '95 ,:,tF!\;f d};C:i_U\Y ~. iT';' ;':i r; , ; {' .~ . 10.1'1. 'I'f .A-- t!+h.f:6 C}- -~. w;U /Iit~. vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-0875 CIVIL TERM : IN DIVORCE LORI J. ATWOOD, plaintiff RODGER T. ATWOOD, II, Defendant AND NOW, this ORDER 01' ~I COURT day of october, 1995, the hearing scheduled in the above captioned matter for Monday, October 23, 1995, at 1:30 p.m. at the Cumberland County Courthouse is hereby continued generally to be rescheduled at the request of either party. '. BY LORI J. ATWOOD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-0875 CIVIL TERM IN DIVORCE vs. RODGER T. ATWOOD, II, Defendant PETITION FOR CONTINUANCE , AND NOW, comes Petitioner, Bradley L. Griffie, Esquire, counsel of record for the above-named Plaintiff, and petitions the Court as follows: 1. The Plaintiff and Defendant were scheduled for a hearing in this matter on October 23, 1995, at 1:30 p.m. ~. Based upon telephone conversations between the Defendant and counsel for the Plaintiff, counsel for the Plaintiff was led to believe that the parties' had reached a comprehensive agreement in this case. 3. Plaintiff and her counsel continue to believe that this matter may be resolved without the necessity of a hearing. 4. Defendant is incarcerated at the Allenwood Federal Correction Institute. 5. Great costs will be incurred by the parties and the Court in order to transport the Defendant to the Court for purposes of the scheduled hearing. 6. Defendant has previously advised the Court of his opposition to attendance at the hearing. 7. Continuing the matter from the present hearing date will allow the parties to resolve this matter without litigation. 8. Continuing the matter will not be a harm or detriment to the either party. WHEREFORE, Petitioner requests your Honorable Court to continue the above referenced hearing, generally. Respectfully sUbmitted, & ASSOCIATES re , ~. Date: VERII'ICATION I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING DOCUMENT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 1~(1S