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Home My WebLink About95-01100 -'I '.'. :i" :1 , '( E t= .,," ',- ~ , " -,'.- b;r ",.\"~; ;;;:~' "'F' :;j"'" ~. .. :'.'.'.:'. -, " -. :". , 8 ,.- ,.- " PHILIP E. TIMM, Plaintiff IN THE COURT OF CU~~lON PLEAS OF CUHBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. SHARON G. TUIM, Defendant NO...JlS-llOO CIVIL TERM AND NOW, this ORDER OF COURT , ,~.' .,..' day of August, 1997, upon consideration of Defendant's Petition To Transfer Venue to Bucks County Court of Common Pleas, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY 'rHE COURT, ,. .....,... /lj " .</ 7 'J~ , Philip E. Timm , 5232 Lovering Drive Doylestown, PA 18901 Plaintiff, Pro Se (' ., ('rl",~~l.l '--l'~u,- <</;l,lh'J ,d,t', Anita F. Alberts, Esq. Suite 201 152 North Main Street Doylestown, PA 18901 Attorney for Defendant :rc ,',- .10..' i.~:1 :.H '"I", , . 'J . .: ~ ..'I j' lb '\I.., ',,'1.1' 'J '.,' ", I\(,,;...~, 1..1 ........~ .;j'l....:Jv :!:)I:J:iO,OJ11.:J ANITA ALBERTS ASSOCIATES Ily: Anita F, Alben!, Esq. Suile 20 I 152 NOr1h Main Slreel Doyleslown. PA 1890 I (215)340'0700 -- fAX (215) 340,2747 vs, IN TIll! COURT Of COMMON PLEAS Of CUMIlERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW IN DIVORCE PHILIP E, TIMM. Plaintiff SHARON G. TIMM Defendant 95,1100 CIVIL TERM OIUlER AND NOW, this dny of , 1997, upon consideralion of Ihe foregoing Petition. it is hereby ordered tnal the enlire domestic file (divorce, eqllitable distribution, and cllstody) pending in Ihe COlllt of Common Pleas in ClImberland COllnty in the lIbove captioned maller be transfcrrcd 10 The Court ofCoJnmon of Bucks COllnty. Pennsylvania. BY THE COURT: J. ANITA ALIlEIlTS ASSOCIATES Ily; Anita 1', Alberts, ESl), Suile201 152 North Main Slreet Doyleslown, PA 18901 (215) 340,0700 FAX (215) 340,2747 PIIILII' E. TlMM, PlaintilT IN TIlE couln OF COMMON PLEAS OF CUMnEIlLAND COUNTY, PENNSYLVANIA VS, CIVIL ACTION, LA IV IN DIVOIlCL; SIIARON G, TIMM Derendnnt 95-1100 CIVIL TEIIM PETITION TO TRANSFER VENUE TO BUCKS COUNTY COURT OF COMMON PLEAS TO TilE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, this ~ day of August 1997. COlllCS Petitioner, SHARON G. TIMM, by and through her cOllnscl, Anita F. Albcns, Esq" IInd respcclflllly reqllcsts This 1I0norable COllrt to entcr IInd Order Trunslerring Vcnllc in this easc lor thc following rcasons: I. A Complaint in Divorce was filed with thc ClIlllberland COllnty COllrl of Con un on Pleas on bchalfofPlaintifT, Philip E. Tilllmlln Fcbrllary 24,1995. 2. A Pctition for Award of Alimony. Alimony Pcndcntc Lite, Coun Costs, COllnscl Fces, and Equitablc Distriblltion was filed with The COllrt on bchalf of Dcfendant, Sharon G, Timm, on April II, 1995. 3. Defendant/Petitioner Sharon G. Timm moved to BlIcks COllnty in JlIly 1996, and Pllrchased a hOllse at 5410 Simpson COllrt, Doylestown, BlIcks COllnty, Pennsylvania, where she currently resides, She also has obtained employment in BlIeks COllnty. _ 4, Plaintiff/Respondent Philip E. Timm, moved to,Bueks COllJ1\y in AlIgllst 1996, and resides at 5232 Lovering Drive, DoylestOlvn. Pennsylvania, S, The minor child of this marriage, Mcgan Irene, also has resided in Bucks COllnty since 1996 and is enrollcd in the Ccntral Bucks School District, Doylestown, BlIcks COllnty, Pennsylvania. 6, A final divorce decrce has not been cntered in ClImberland COllnly, 7, Venlle is no longcr proper in ClImberland COllnly and should bc transferred to BlIcks COllnly COllrt of Common Pleas, WHEREFORE, Defendant/Petitioner reqllests This Honorable COllrtto enter an Order lransferring all action inlhe above case to thc Prothonotary of the BlIcks County Court of Common Pleas. Respectfully sllbmitted, Date: ANITA ALBERTS ASSOCIATES By_{i;J; (j)tfr ANITA F, ALBERTS Attorney 1.0, 1128086 Attorney for Defendnnt 7'L 2 , , , VERIFICATION I, Sharon G. Timm, do hereby verify that lhe statements Illade in the foregoing Petition to Transfer Venue to Bucks County are true and correct to the best of my infonnalion and belief. I understand thai false statements herein arc made subject to the penalties of 18 Pa. CS ~4904 relating to unsworn falsilicalion to authorities, --LJ\^'f'n ~I ';lql!t1I~AYl SHAR NG.TI ~ Sworn to and subscribed to before me this .~ day of ~.a:t:' ,1997. (}~/IJbiw' Notary Public Notorla' Soal Palrlcla A, Wober. Nolary Publlo Dol10stown 80'0, Bucks County My Commission e'p1res March 5, 2001 Member, Pennsylvania Association 01 Nolarles , '.~" ,,,"~~-j','-,,,,*"~~~., .. ,; I- ---_..__-'.._''';;t.a'lo.t ~--=--::;.~~ , ~., . ,,', " . , " " ANITA ALBERTS ASSOCIATES By: ANITA F. ALBERTS, ESQUIRE Attorney I.D. 28086 152 Nonh Main Streel. Suite 20 I Doyleslown. PA 1890 I (215) 340,0700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LA W PHILIP TIMM. Plaintiff. No. 95-1100 CIVIL TERM v, IN DIVORCE SHARON G. TIMM, Defendant. WITHDRAWAL 0/1 APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance as cOllnsel for Defendant, Sharon G, Timm. relative to the above-captioned maller, Date: .4 ' 7 - " 7 \, _J.\.\.~-t.(tLt iL.r- RUBY D. WE! S. ESQUIRE lOWest High Street Carlisle, PA 17013 (717) 243-1294 ENTRY OF AI'I'EARANCE TO THE PROTHONOTARY: Kindly enter my appearance as cottnsel for Defendant, Shuron Q, Tinull. relative to the fk~ ibki& ANITA F, ALBERTS. ESQUIRE 152 North Main Street. SlIite 20 I Doylestown, PA 18901 (215) 340-0700 Dute: 3 / 997 ItATHGEBElt & ASSOCIATES BY: JILL M, VOGENBEltG, ESQUlltE Morney ID No. 70209 III East Court Slreet Doylcstown. PA \8901 (215) 340-0400 IN THE COURT OF COMMON PLEAS OF CUMBEltLANI> COUNTY, I'A CIVIL ACTION - LAW PHILIP TIMM PlaintilT No, 95-1100 Civil Term v. SHARON G. TIMM Defendant IN DIVORCE WITHI>RA W AL OF AI)PEARANCE TO THE PROTHONOTARY: KINDL Y WITHDRAW my appearance as cOllnsel on behalf of the Defendant. Sharon G. ::~m~ W~~;:j ;b"'~"P'i"~ m"'" By -~~;L @bi.." I I 301 South Main Street Thc Atrillm, SlIile W-2 DoylcstolVn, PA 18901 (215) 340-0700 ENTRY OF API'EARANCE TU THE PROTHONOTARY: KINDLY ENTER my appearance as cOllnsel on bchalf of, Dcfendant. Sharon Gilbert Timm, with regard to thc abovc-captioncd mallcr RA TI-IGEBER & ASSOCIATES Datc; /fJ/rXbltJ)J , " BY: /70209 ..., \I JUN 2 8 1(1(1:: kt>J JUI/ 29 Z .:~ PII'95 , , PHILLIP E. TIMM, Plaintif:f '\"; : IN THE COURT OF COMMON PLEAS OF :CU~!BERLAND COUNTY, PENNSYLVANIA v . . :NO. 1100 - CIVIL - 1995 . . SHARON G. TIMM, Defendant . . :CIVIL ACTION - CUSTODY COURT ORDER AND NOW, this '2.,(t,day of ~"YJ It:.. , 1995, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Phillip E. Timm, and the Mother, Sharon G. Timm, shall enjoy shared physical and shared legal custody of Megan Irene Timm, born September 17, 1988. 2. Physical custody shall be handled with the partie!! alternating custody on a week to week basis with the exchange of custody taking place on Friday evening at approximately 5 P.M. or at such other time as agreed by the parties. 3. The non-custodial parent shall also be afforded at least two evenings per week with the minor child from between approximately 5 P.M. and 8 P.M., the days during the week to be agreed upon by the parties. 4. The alternating week schedule shall commence as of August 4, with the parties arranging the physical custody as they might agree up until that time. 5. Upon either party relocating from the Cumberland County area and in the event the parties are not at that time able to reach an agreement with respect to a permanent custody Order, counsel for either party may contact the Custody Conciliator to have the ease scheduled for another Custody Conciliation Conference. BY THE COURT, co: Hi,h.., L, 8..gs, ESQUiro-1' Lfl..4J 04.1 Ruby D. Weeks, Esquire ~ ~.t t,,/A.q /91;. ~. ('. " ' . . _.' <::'" ,,' ., ,'.:..~'.~;~~':::::::::~ "''1t .... l. :! SHARON G. TIMM, Defendant . . :CIVIL ACTION - CUSTODY PHILLIP E. TI~~, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v . . :NO. 1100 - CIVIL - 1995 CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Megan Irene Timm, born September 17, 1988. 2. A Conciliation Conference was held on June 21, 1995, with the following individuals in attendance: The Father, Phillip E. Timm, with his counsel, Michael L. Bangs, Esquire, and the Mother, Sharon G. Timm, with her counsel, Ruby Weeks, Esquire. 3. The parties agreed to the entry of an Order in the form as attached. v!;;r.,/q.r DATE t Hubert X. Gilroy, Esquir Custody Conciliator . 1 ,I vs. IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA eIVIL ACTION - ~W CUSTODY PIIILLIP E. TIMM, Plaintiff/Respondent SIIARON G. TIMM, , Defendant/Petitioner 95-1100 CIVIL TERM ORDER OF COURT AND NOW, this ~~(~ day of f'-pr,' , , 19 ~~upon consideration of the attached Complaint, it is hereby directed, that the parties and their respective counsel appear before ~H.,bt'rr :f.. (,\ (01 E1,the conciliator, at ~tA, frO(1( (.,,,,6,[,,, 0.rI ~~~L the ..J2l!"'day Of' M\ 'I , 19~~ ':;'1.7 1.1 ( at ~ --Lr.m., for a Pre-Hearing custody conference. At such conference, an effort will be made to resolve the issues in disputel or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary Order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. Until such time as the parties meet with the conciliator, the parties are directed that the custody of the child is not to be changed from the mother. FOR THE eOURT, ,~.,'~ By: custody Conciliator 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 OIlT WHERE YOU CAN GET LEGAL HELP. court Administrator Fourth Floor Cumberland County courthouse earl isle, pennsylvania 17013 . PHILLIP E. TIMM, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA va. CIVIL ACTiON - LAW CUSTODY SHARON G. TIMH, Defendant/Petitioner NO. 95-110D CIVIL TERM OROER OF COURT YOU, PHILLIP E. TIMM, Plaintiff, have been sued in Court to obtain custody, partial custody or visitation of the child, Megan Irene Timm, born 9/17/88. You are ordered to appear in person at Courtroom No. County Courthouse, carlisle, Pennsylvania, on , eumberland , the_ of , 19_, at __.M. for a hearing. Until such hearing, custody of the child shall be and remain with the natural mother, SHARON G. TIMM. If you fail to appear ao provided by this order, an Order for cuotody, partial custody or vioitation may be entered againot you or the Court may iooue a warrant for your arreot. 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 courthouoe carliole, Pennoylvania 17013 Telephone. (717) 240-6200 BY THE COURT, J. PIIILIP E. TIMM, Plaintiff/Respondent IN TilE COURT OF COMMON PLEAS OF eUHBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW eUSTODY VB. SIIARON O. TIMM, Defendant/Petitioner NO. 95-100 CIVIL TERM COMPLAINT FOR JOINT AND SIIARED CUSTODY TO THE II0NORABLE, THE JUDOES OF SAID COURT I 1. The Plaintiff is, PHILIP E. TIHM, hereafter refer~ed to as the natural carlisle, eumberland father, residing at 1200 Redwood Hills Circle, County, PAt 17013. 2. The Defendant is SHARON G. TIMM, hereafter referred to as the natural mother, residing at 1200 Redwood Hills eircle, carlisle, eumberland County, PA 17013. 3. Defendant seeks legal cuetody of the following child. a. Name Present Reoidence 89!! Megan Irene Timm 1200 Redwood Hills eircle Carlisle, PA 17013 6 b. The child was born on September 17, 1988. c. The child is preeently in the custody of the natural mother, who resides at 1200 Redwood Hills eircle, carlisle, Cumberland county, PII, 17013. d. The child has reeided with the following pereons and at the followin9 addresses for the past 16 months. Persona IIddress Dates Philip & 1200 Redwood Hills eircte 1988 Sharon Timm Carlisle, PII 17013 to 1995 e. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another Court. , Plaintiff has no information of a custody procseding concerning the child pending in a Court of this Commonwealth. 4. Defendant does not know of a person not a party to the proceedings who has " !t 3. physical custody of the child or claims to have custody or vieitation rights with respect to the child. 5. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child has been named as parties to this action. There are no other persons who are known to have or claim a right to custody or visitation of the child, so none will be given notice of the pendency of this action and the right to intervene. 6. Pursuant to the eustody and Crandparents Visitation !let, the mother requests this court to grant an award of legal custody to her. 7. The Mother requests physical custody of the child in that she is in a better position to provide consistent and stable care for the child and she is the parent more likely to assure that the child have a relationship with both parents. 6. The best interests and permanent welfare of the child and her physical, spiritual, emotional and moral well-being will be served by granting the relief requested of legal and physical custody with the Mother. 9. Defendant, Mo:her prays for an Order awarding legal custody of the minor child, Megan Irene Timm, born September 17, 1966, to the Defendant and with partial custody awarded to Plaintiff as this court determines is in the best interests of the child. WHEREFORE, Defendant, Mother prays for an Order awarding legal custody of the minor child, Megan Irene Timm, to the Mother, with actual physical custody to the Mother. Respectfully submitted, Datel~)',:Q ..- /I . I '/'1 ~ , es~~ (<Ld-.4- Ruby D. ~eeks, Esquire !lttornsy for Defendant 10 West High Street Carliulo, Pennsylvania 17013 II I I , ! , I PHILIP E. TIMM Plaintiff IN THE COURT OF COMMON PLEAS -OF CUMBERLAND COUNTY. PENNSYLVANIA vs. I I , , SHARON G. TIMM Defendant CIVIL ACTION - LAW NO. 95- 1100 CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGIITS You have been sued in court. If you wish to defend against the claims set forth in foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be ,entered against you by the court. A judgment may also be entered against you for any 'other claim or relief requested in these papers by the plaintiff. You may lose money or iproperty 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 counneling. A list of marriage counselors is ! available in the Office of the prothonotary at: Office of the prothonotary Cumberland County Court House Carlisle, pennsylvania 17013 , , 11 :i i i IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR IEXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE TilE RIGHT TO CLAIM ANY I,OF THEM. II Ii YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT IIAVE A LAWYER OR 'ICANNOT AFFORD ONE, GO TO OR TELEPIIONE THE OFFICE SET FORTII BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL HELP. I Court Administrator, Fourth Floor Cumberland County Court 1I01lse Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 1 . II il !IPIIlLIP E. THIM ~ i Plaintiff ji " II vs. I SHARON G. I I , I , I ! IN TlfE COURT OF C0l1l10N PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TIMM Defendant NO. 95- //00 CIVIL TERM IN DIVORCE NOTICE OP AVAILABILITY OP COUNSBLING liTO TlfE WITIIIN-NAMED DEPENDANT: I I' :1 dn You have been named as the Defendant in a Compiaint in a divorce proceeding filed the Court of Common Pleas of Cumberland County. This notice is to advise you that in Ii 'Iaccordance with Section 3302(dl 01 the Divorce Code, you may request that the court ! !!require you and your spouse to attend marriage counseling prior to a divorce being " iihanded down by the court. A list of professional marriage counselors is available at :ithe Domestic Relations Office, 13 North Ifanover Street, Carlisle, Pennsylvania. You are Ii I,advised that this list is kept as a convenience to you and you are not bound to choose !Ia counselor from this list. All necessary arrangements and the cost of counseling II ' [I sessions are to be borne by you and your spouse. , If you desi re to pursue counseling, you must make your request for counseling I Iwithin twenty days of the date on which you receive this notice. Failure to do so will II IIconstitute a waiver of your right to request counseling. I, ii I " , I i I I 2 , I I ,'PIULIP E. TIHH ; ! Plaintiff t,: r I: I IN THE COURT OF COHHON-PUEAS OF CUHBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 95- /1111) CIVIL TERH IN DIVORCE : SHARON G. TIHI1 Defendant i: II COHPJ.AINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF filE DIVORCE CODE AND NOW comes the above-named Plaintiff. PIlILIP E. TIHH. by his attorneys. Andes, ::Vaughn & Bangs. and makes the following Complaint in Divorce: 1. The Plaintiff is PHILIP E. TIHI1, an adult individual who currently resides at 1200 Redwood Hills Circle. Carlisle. Cumberland County, Pennsylvania. 2. The Defendant is SHARON G. TII1H, an adult individual Io/ho currently resides at 1200 Redwood Hills Circle. Carlisle. Cumberland County. Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- iwealth of Pennsylvania for at least six months immediately previous to the filing of ,this Complaint. 4. The Plaintiff and Defendant were married on 21 April 1986 in Pluckemin, New Jersey. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 1. Plaintiff has been advised of the availability of marriage counseling and the 'i Piaintiff may have the right to request that the Court require the parties to partici- ! pate in counseling. 3 , 8. The Plaintiff requests this Court to-enter a Decree of Divorce. ~IBRBFORB, Plaintiff requests this Court to enter a decree in divorce pursuant to I the Divorce Code of Pennsylvania. I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). I'I' f'( 6-"",','(j I Date 'I I; II I; ,t I' ., dL(. 1'1''/''- at I' PHILIP E. TIHH -" / "..,~ Ii 4 \., :l I 'I PHILIP E. TIMM Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. SHARON G. TIMM Defendant CIVIL ACTION - LAW NO. 95- 1100 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE BY CERTIFIED HAIL LOU ANN GRISSINGER, being duly sworn according to law, deposes and says as follows: 1. That she is an employee of Andes, Vaughn & Bangs, attorneys tor the Plaintiff I herein. 2. That on 3 March 1995, she delivered to the U.S. Postal Service in Lemoyne, pennsylvania, as certified mail (Receipt No. 2402 531 016) return receipt requested, addressed to the Defendant herein, a true and correct copy of the Complaint in Divorce filed in the above-captioned action duly endorsed with a Notice to Defend and Claim Rights. 3. Said returll receipt card is attached hereto as Exhibit A showing a date of delivery to the Defendant of 4 March 1995. Sworn to and subscribed before me this 21'" day of r,^,,^c.~ ,1995. ~.D \ J\..Ltir~l J~::.\} rJC;) Lou Ann Grissinge~) L Notar .,.., Public Notnll...d St'lll Lynn K'rolf, ljo!.lI'1 1\4>>C t..omoyro Boro. COHo,lmJ t;<>ftllV My COH......W1 E>\lfl15l\1llj II. to'JO , I ,.. II SE DEn: ~ . Complell Item. I Indlor 2 for Idditlon.lllrvlc... I also wish to receive the G . Compl'I' Item. 3. end .c. & b. following servIces lIor an oxtra ~, r! . Print your nlm. end .dd"" on the rev.,.. 01 thl. form .0 th.t w. un foo): .~ G ..turn \hI. c.rd 10 you, I;, = ' AtI.th Ihl. 'orm 10 th. fronl of th. m.l1plece. or on the b.ekU .plce 1. 0 ~rS~'~A d~8r ~ ~~e.~~~k, ^~ ~ _ !!, ,It,''R.turnA.tlllpIRllqulIllld''onthtm.llplec.bllowthe.rtltlenumber. 2. VAas Mf:ted sllvorv .ell ~ . he Aelurn ReclIlpl wlll.how 10 whom the .nlelo WII dlllv.red.nd th. d,tI , A g d. ver.d. Consult ostmaster for feo. G 'tl Artlcl. Add'....d to: 4.. Artlcl. Numb., a: i S~l1rorl G. T.",,,,, l./Ol ~37 olG ~ E U 'II I 4b. S.,vlc. Typ. tl! 8 \'1.00 R.&,.,,,,,&' III sCire <., 0 R.glstorod Olnsur.d . " I ' l' 01 Ulc.....-\, ,\c P A . fl1 b 13 ~ Cortlfl,d 0 COD .Ii 13 0 Expro.. M.II 0 R.lu," R.c.lpl for g a: . rc B dlse .. IS L,; 7. D.to of D.llv.r ol! ct 6 i 5. 51 .tur. IAddros, .' od; ~ 6:5 r"f'l. urrllA91.11l I,' 1'111: If I' ' I l o Ii,,, I , ,;- PS F?rm , D.c.mb.r 1991 . _u.s.aPO: "..--352.7\4 E)J,b,+ A PHILIP E. TIHM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBEIlIJlND counTY, PENNsn.VANIA : - CIVIL ACTION - IJIW IN DIVORCE VB. SHARON G. TIHM, Defendant 95-1100 CIVIL TERM PETITION FOR AWARD OF ALIMONY. ALIMONY PENDENTE LITE. COURT COSTS. COUNSEL FEES. And EOUITABLE DISTRIBUTION TO TilE IIONORABLE, TilE JUDGES OF SAID COURT. COMES NOW, Defendant, Sharon G. Timm, by her attorney, Ruby D. Weeko, Eoquire, and she reopectfully represents that. 1. Plaintiff io PIIILIP E. TIMH, an adult individual reoiding at 1200 Redwood lIillo Circle, Cumberland County, Pennoylvania, 17013. 2. Defendant io SIIARON G. TIMM an adult individual reoiding at 1200 Redwood Hillo Circle, Cumberland County, Pennoylvania, 17013. 3. Plaintiff and Defendant are huoband and wife. having been married on April 27, 1986. Plaintiff filed a Complaint in Divorce on February 24, 1995. REOUEST FOR DIVISION OF PROPERTY 4. The partieD purchaoed or otherwioe obtained during the couroe of their marriage property which io conoidered "marital property". 5. Upon entry of a divorce decree, ouch property ohould be divided equitably aD io juot and proper. COUNSEL FEES. COSTS. EXPENSES 6. Defendant, Sharon G. Timm, haD retained the oerviceo of Ruby D. Weeko, Eoquire, and the counoel feeD, coots, and expenoes for repreoentation in th\s action will be subotantial and continuing. 7. Defendant io without oufficisnt fundo, income, or assets tiJ pay ouch counsol feoB, coote, and expenses. 8. Defendant will need to retain the services of an appraiser and other experts with regard to this action. 9. Plaintiff is financially able to p,'ovide for thoDe expenseD of Dofondant. . . , ~. . _.....--r--.:...~-_-..-. . . .. , I' .~ _'._ __..._____n . L ALIMONY AND ALIMONY PENDENTE LITE 10. Defendant lacks sufficient means of support at present to fully provide for her reasonable needs, in that she is not currently employed. 11. Defendant requests an award of alimony psndente lite. 12. Defendant requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. 13. Plaintiff is financially able to provide for the reasonable nseds of Defendant. WIlEREFORE, Plaintif f prays that Your lIonorable Court enter an award for equitable distribution of property, counsel fees, costs and expensee, alimony and alimony pendente lite, and insurance relief in favor of the Defendant and against the Plaintiff. Respectfully submitted, . -- Dated, 1/.//':.-'::> \ ' <"' \ ~ 'I' , L, \. '. k .- o.- . ,.......... Ruby D. ~eeks, Esquire Attorney for Defendant 10 West High street Carlisle, PA 17013 (717) 243-1294 tC: SllllUcI L. Andes, Eaquirc, PI.inlifT Ruhy O. Wee"', EJquire, lkfcflt.lllnt oR '5/vfd.. ftfJ JI--5 "78'" RAT/WEDER & ASSOCIATES BY: JILL M. VOGENDERG, ESQUllm Atlomey 10 No, 10209 III Easl COUlt Street Doyle'lown. PA 1890 I (215) 340.0400 IN THE COURT OF COMMON I'LEAS OF CUMBERLAND COUNTY, I'A CIVIL ACTION . LAW PHILIP E. TIMM Plaintiff No. 95. I 100 Civil Term v. SHARON G. TIMM Defcndnnt IN DIVORCE RULE ABSOLUTE AND NOW. this \.2..I~ dny of -f-J eve. .... ~()', 1998. thc Rule elllered August 22, 1997 is madc ABSOLUTE, nnd thc venue of Defcndunt's cntin: domestic liIe (divorce. nlimony, APL. court costs. ullorncys' fccs. cquitublc distribution nnd custody) pending in the Court of Common Pleus in Cumberlnnd County in the ubove captioncd ll1allcr ~hall bc transferred.to ~hc Conrt ~fColl1mon Plca~ orBueks Coullty. pennsylvunin. Ait c.u. 'T r-;.c.-':, f'L!....t~\.?I~\ r" ii-1f.':>tl!)l~.kr of VONG ,..~,.!ll L~ 1;)10..:/"),'10,,:.( b-\ Dc~,LJ7t, BY TIlE COURT: iLL, J, RATlIGEDElt & ASSOCIATES IIY: JII,L M. VOGENIIEItG, ESQUlltE Auorney ID No, 70209 III Ensl Court Street Doyleslown. PA 18901 (21 S) 340.0400 IN THE COURT OF COMMON "LEAS OJ:.. CUM8ERLAND COUNTY, PA CIVIL ACTION - LAW PHILIP E.TIMM Plaintiff No. 95.1100 Civil Term v. SHARON a. TIMM Defcndant IN DIVORCE AND NOW, this PETITION FOR RULE ABSOLUTE . 'C'..... /f7/ -/ ~ 9 day of LY c..u.t....-t..... . 1998 comes Delcndanl. Sharon Gilbcrt Timlll, und requests This Ilonorublc Court to enter a Rulc Absolute permitling Dcfendant to transfer vcnuc of the cnlire cllPtioned Cllse to Bucks County Court of Common Plells. and avcrs as follows: I. On August 7,1997, Delcndunl pctitioncd for Rulc to Show Cause why she should not bc pennittcd to transfer venue of the entire captioncd case from thc Court or Common Pleus. Cumbcrland County, PA to thc Court of Conlin on Picas. Bucks County,PA. 2. An Ordcr for Rulc to Show Cause IVas entercd by Thc Honorable J. Wesley Olcr, Jr. on August 22, 1997 with a Rule Returnable date of twenty duys of service. This was scrved upon counsel for Plaintiff on August 19. 1997. A true und correct copy of said Petition and Rule und uccolllpanying correspondcnce is utlllched hercto liS Exhibit "A". 3. No response to the pelition und Rule was rcceived und onc (I) year hus elupscd beyond Ihe return date. WHEREFORE, the undersigned counsel respectfully rcquests thc Rule cntered on August 22, 1997 be madc ABSOLUTE und thc venuc of thc cntirc captioned domcstic casc (including divorcc, nlimony, APL, court costs. allorney Ices, cquitllblc distribution and custody) be trunsferrcd frolllthe Court of ComlllonPlclIs of Cumberland County to the Court of Common Picas of Bucks County, P A . Rcspectfully submiucd. RATHGEBER & ASSOCIATES Dutc:_' O. 2. 9 - ~ I(? B VEIUFICATION I, Jill M. Vogcnbcrg, Esquire, attorney for Defendant in the above-captioned matter do hereby verify that I am authorized to make this Verification and that the statements set forth in the foregoing Petition far Rule Absolute lire true lInd correct to the best of my knowledge, information and belief: I understand that false statcmcnts hcrcin lire madc subject to the penalties of 18 PlI. C.S. ~4904 relating to unsworn falsi fication to authorities. DATE:~ ,'! I j " ANITA ALBERTS ASSOCIATES ATTOMtvs AT LAw 152 NOSlIH MAIN STFll:[f SUITE 201 OOYlESTtMN. PA 18901 : , I, :i!'~.3.100700 [ FAX a".J4C>~.;'7'i'7 " 5' MAO~ AVENUE SUITE 450 MQAAISTQlNN. NJ 07960 2ot'm,aaJ2 _A F, AlDEI1IS SIWlON ~EI1T TW.' PAfRClA WEBER PAAALEOAL "LSO ADf.NTTtO IN NJ' August 6, 1997 Office of the Prothonotary Cumberland County Court of Common Pleas Cumberland County Courthouse High and Hanover Streets Carlisle, PA 17013 Re: Thnrn v. Tirnrn #I 95-1100 Dcar Prothonotary: Enclosed for filing is a Pctilion to Transfer Vcnue to Ducks County Court of Common Pleas in the abovc captioned action. Please send a tirnestarnpcd copy of samc in the postage paid envelope enclosed. Also, arc copies of the accompanying Order for PlaintifflRespondent and DefendantlPetitioncr with self.addressed, stamped cnvelopes for each. Very truly yours, f);~~ AFA:pw Enclosures '. ANITA ALBERTS ASSOCIATES A~AT lJ,w 152 NoRTH MAlN 6lRET Sure 201 00vusTtmN, PA 18901 mTA F. ~ERTll SHAAON OlBEnT~' PATAlCIA \M1lEA PAAAUlIAI. 215-:1400700 FA)( 215-:14G2747 1515 MAD~ A'vtMJ: 6lJ/T'E40l0 MCmISTCJ'MoI. tlJ 071l6O 201.,;)lJ.2002 .. AlSO AOfdTTEO"" NJ' August 18, 1997 Samuel L. Andes, Esq. 525 North Twelfth Street P.O. Box i68 Lemoyne, PA 17043 Re: Timm v. Timm 95-1100 Dear Mr. Andes: Enclosed is a Petition to Transfer Venue to Bucks County in the above mailer. I apologize for the delay in sending this document to you. Mr. Timm advised our office he would bc engaging local o;ounsel in Bucks County. However, since you are still the attorney of record in Cumberland County in this case, The Court has indicated you must receive a copy of this Petition. AFA:pw Enclosure PIIILIP E. TIMM, Plaintiff IN TilE COURT OF CmlMON PLEAS OF CUHBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. SIIARON G. TIMM, Defendant NO.-95-1100 CIVIL TERM I " ORDER OF COURT AND NOW, this 22."1J day of August, 1997, upon consideration of Defendant's Petition To Transfer Venue to Bucks County Court of Cornmon Pleas, a Rule is hereby issued upon Plaintiff to show cause why the relief r.equested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Philip E. Tirnm 5232 Lovering Drive Doylestown, PA 18901 Plaintiff, Pro Se Anita F. Alberts, Esq. ~ite 201 ~~~2 North Main Street Doylestown, PA 18901 Attorney for Defendant TRUE COpy FROM RECORD In Tostlmony ViI1'r~of, I h'.r~ unto set my ha.t and Iho seal of SJid Court at Carlislo, Pa. ThIs ...R7..;?~ day of....~,n...' 19..9.1 .,..."..~....a..:..7.f'~...._ r13;d1: ProthOnomy :rc ANITA ALBERTS ASSOCIATES By: Anila F. Alberts, Esq, Suite 201 152 North Main Street DoylestQIVI1. PA 1890 I (215) 340-0700 FAX (215) 340-2747 PHILIP E. TIMM. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA vs, CIVIL ACTION . LAW IN DIVORCE SHARON G. TIMM Defendant 95.1100 CIVIL TERM ORDER AND NOW, this day of , 1997, upon consideration of the foregoing Petition, it is hereby ordered that the entire domestic file (divorce, equitable distribution, and custody) pending in the Court of Common Pleas in Cumberland, County in the above captioned matter bc transferred to The Court of Common of Bucks County, Pennsylvania. BY THE COURT: J. ANITA ALBERTS ASSOCIATES By: Anit3 F. Alberts, Esq, Suite 20 I 152 North M31n Streel_ Doyleslown. PA 18901 (21 S) 340.0700 FAX (2IS) 340.2747 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LA W IN DIVORCE PHILIP E. TIMM. PI31nliff SHARON G. TIMM Defend3nl 95-1100 CIVIL TERM PETITION TO TRANSFER VENUE TO BUCKS COUNTY COURT OF COMMON PLEAS TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, this 1:&.- day of August 1997, comes Petitioner, SHARON G. TIMM, by and through her counsel, Anita F. Alberts, Esq., and respectfully requests This Honorable Court to enter and Order Transferring Venue in this case for the following reasons: I. A Complaint in Divorce was filed with the Cumberland County Court ofCornrnon Pleas on behalf of Plaintiff, Philip E. Timm on February 24, 1995. 2. A Petition for Award of Alimony, Alimony Pendente Lite, Court Costs, Counsel Fees, and Equitable Distribution was filed with The Court on behalf of Defendant, Sharon G. Timm. on April 11, 1995. J, DefendantIPetitioner Sharon G. Timm moved to Bucks County in July 1996, and purchased a hOllse at5410 Simpson Court, Doylestown, Bucks County, Pennsylvania, where she currently resides. She also has obtained employment in Bucks County. 4. PlaintifflRespondent Philip E. Timm, movcd to Bucks County in August 1996, and resides at 5232 Lovering Drive, Do)'lestown, Pennsylvania. S. The minor child of this marriage, Megan Irene, also has resided in Bucks County since 1996 and is enrolled in the Central Bucks School District, Doylestown, Bucks County, Pennsylvania. 6. A final divorce decree has not been entered in Cumberland County. 7. Venue is no longer proper in Cumberland County and should be transferred to Bucks COllnty Court of Common Pleas. WHEREFORE, DefendantIPetitioner requests This Honorable Court to enter an Order transferring all action in the above case to the Prothonotary of the Bucks County COllrt of Common Pleas. Respectfully submitted, Date: ANITA ALBERTS ASSOCIATES B".~ (])W ANITA F. ALBERTS Allome)' 1.0. #28086 Allomey for Defendant "., 2 VERIFICATION I, Sharon G. Timm, do hereby verify that the statements made in the foregoing Petition to Transfer Venue to Bucks County are true and correct to the best of my information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. CS ~4904 relating to unsworn falsification to authorities. ~\^I1i'n ~1"l~[~~'hYl SHAR N G. TI Sworn to and subscribed to before me this -~ day of dd'c;t;' . 1997. (JdA~1 Jt~./ Notary Public Notarial Seal Patricia A. Weber. Notary Public Doylestown Boro. Bucks CounlY My Commission Expires March 5. 2001 Member. Pennsylnnla ASsoclalion 01 Nolarlll ANITA ALDERTS ASSOCIATES Dy: Anha F. Albens, Elq. Suhe 201 152 North Main Street DoyleltolVn. PA 1890 I (215) 340.0700 FAX (215) 340.2747 VI, IN THE COURT OF COMMON PLEAS OF CUMDERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LA W IN DIVORCE PHILIP E. TIMM. Plaintiff SHARON G. TIMM Defendant 95.1100 CIVIL TERM CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this date a copy of Petition to Transfer Venue to Bucks County Court of Common Pleas and this Certificate of Servicc werc served upon the individual listed below via first class regular mail addressed as follows: Samuel L. Andes, Esq. 525 North Twelfth Strcel P.O. Box 168 Lemoyne, PA 17043 ERTS ASSOCIATES Date: By: ANITA F. ALBERTS Attomey 1.0. 1128086 Attomey for Plainti ff , .'