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Home My WebLink About95-02842 ~ I i I '3 1 (1 , 'I , C I I C I ',J j d "'-"'..... ~ J , i I ~; , I -.91 ~I I ~ ~ ~ ~ I iHi ~ ~ ~ ~ ~ ~ ~ ~ i ~ ~ 0: j ~ i3 ~ .. \ ., . I~ ! ~ ~ '-9 ,1 ~ JANE MARIE QUlNN, Plainli rr 1 N 'I'm; COUll'l' 0)0' COMMON PLI,AS CUMIlEIlLANll COUNTY, PENNSYI.vAN I A NO: 95-~642 ClVIL 'I'EIlM v. SIfAWN E. QUINN, Pufundunt IN 11 I VOIleE OIWI':I< OF COUI<'I' And now lhis J'I day of Junu, 1995, upon consideration of Pelilioner's Petition to Prevent IJlssip<llion of Marital Property and Exclusive P088usslon 01 the Mini tal hOllie, whlt:h Pelilion was duly Bel'ved on thu Iluspondunl on June 1, 1995, and atter hearing to which the Ilespondent lallud to ullend, il 1a hereby ordered and decreed: 1) Pelilioner, Jane M. \,lulnn, lor herself and for I.he minor children, 'l'caguc (IlOIl 12/13/62) ami Fagan (DOll 12/9/115), Is hereby awarded exclusive possession of tho mal'ital home al 722 Kent Drive, Mechanicsburg, Cunilierland County. Pennsylvania. Ilespondenl, Shawn E. Quinn is prohlblled frolll Ilntry on [0 thu aforesaid property exccpl a8 same may bo oxprellsly alluwed by I'ulilioner. A copy of lids ordcl- shall be provided to thu Ifamden 'I'ownuhlp 1'011ce Dopartmenl for unlorcelllenl.. 2) llo11pondont, Shawn I':. \,luilln, Is spot:ifically prohibiled from soil iny, tl'lHllllurrlll<l. i111'''l()tl/l'J, [lildlny or In any olher way dlspOllllllJ of or IJIlculllbnr iny any lIIi1rllal or sIngular Iy tltlcd propurty, purslJIlul or rlhll. IllJ/;pondunt III IIpuclfically prohlbiled from uxl.orHlllIlJ thu Ilxlllllny li/lo 01 crUlllt whIch oxistll through Momlwrll Flrlll Crudil Ilnlon on tho milrital JU1l1dill1C1l locatud Ill. 722 Kenl llrlvll, MlldliWI(:/JIJlllIJ, 1'(!Il/lsylvllJllil. HUlipondont III fur-IImr prohibited from creating any additional debt for which the parties may become obligated. Respondent is further prohibited from removing from the marilal home any items of personal property. 31 The remaining severance check which Respondent is to receive from his prior employer, PIIICO, shall be tendered by PllICO to Petitioner for her use in paying marital obligations, including but not limited to, the morlgage. Notice of this order shall be promptly delivered to PIIICO which is directed to make said check, and any additional checks which may be due to Respondent, payable directly to Petitioner, Jane E. Quinn, In the event that said sums are already forwarded by PIIICO prior lo receipt of said order, Respondent is specifically directed to remit said check or the proceeds of same to Petitioner for use by Petitioner to satisfy marital debts and for her support and the support of the children, 41 Pending further order through Domestic Relations, Respondent is hereby directly to remil to the Petitioner from his Unemployment Compensation the sum of eleven hundred dollars per month ($1100.001 in bi-weekly installments of five hundred fifty ($550,00) to be used for Pelitioner's support, the support of the parties' children and payment of the mari tal debts. Said payments shall be made within twenty-four (24) hours of Respondent' B receipt of said funds. / BY TilE COUHT: :'~i The 1I0nOra~dgar } B, Bayley JANE MARIE QUINN, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. SHAWN E. QUINN, DEFENDANT J...../J.. 95.2&4e;CIVlL TERM ORDER OF COURT AND NOW, this " ~ day of July, 1995, a Rule Is entered against defendant, Shawn E. Quinn, to show cause why he should not be adjudged In contempt of thlll Court's order of June 27, 1995. Rule returnable In Courtroom Number 2, Cumberland County Courthouse, Carlisle, at 10:30 a.m., Monday, August 7, 1995, at which time defendant Is ordered to appear. By the Court, . I I \\ tx / '--~J/I'). \~ Edgar B. Bayley, J. ( Shawn E. Quinn, Pro se c/o Mr. William Quinn 35 S. 18th Street Camp HIli, PA 17011 Barbara Sumple-Sulllvan, Esquire ) For Plaintiff ( ) F 1'1 ('f I I n 'r/ :888 fJ -, ~ " 01 ~ ~ 3 i ~!~ r ~ ~ ~ ~ in ~ ~:3 i i ~ 0 ; Ln .' rn .f; . .. '.:, ," C) ('0"") f^'- " . JANE MAIlI~ QUINN, Plaintiff v. IN 'I'IIE COUIl'I' OF COMMON PLEAS CUMBEIlLAND COUNTY, PENNSYLVANIA NO: 95-2842 CIVIL TEIlM SIIAWN ~, QUINN, IN DIVOIlCE Defendant 1>1~'I'I'I'lON ~'OI~ CON'I'EMP'r 1, Petilioner is Jane Mario Quinn, who resides at 722 Kent Drive, Mechanlcsburg, Cumberland County, Pennsylvania, 2. Ilespondonl is Shawn E, Quinn, who resides with his parents al 35 S. 18th Slroel, Camp lUll, PA 17011. 3, On June 27, 1995, lhe lIonorable Edgar B. Bayley entered an Order lo Prevenl 01 ss i palion of Mar i lal Property and granted excluaive possossion of lhe marital home lo the Petitioner, A copy of said Order is allached herelo as Exhibit "A". 4. Since lhe enlry of said Order, which Order was served on the Ilespondenl by fil'sl class mail and which receipl pelitioner can verify, the Ilospondenl has willfully failed to obey said Order as follows: a. Ilespondonl received an insurance claims check In lhe amount of 'l'wo 'j'housand Sill lIundred and Twelve [Jollars and 62/100 ($2,612.62) un June 29, 1995. 'I'ho check was lo pay a claim for 2 damages to the parties' van arising from the Respondent hitting a parked car. said check was made payable to bolh Pel! tioner and Respondenl. Respondent forged Petitioner's name and deposited said check into his checking account, less Five lIundred 'I'welve Dollars and 62/100 ($512.62). Such action is in violation of paragraph 2 of the aforementioned Ol'der of Court, wherein Respondent is specifically prohibited from selling, transferring, alienating, trading or in any other way disposing of or encumbering any marital or singularly titled property, personal or real. While Petitioner ~ I, was able, through intervention of the insurance carrier, to ~ preserve the balance of two thousand ono hundred dollars ~ ($2,100.00), the remaining five hundred and twelve dollars 62/100 ($512.621 has been taken by Respondent. b. On July 1, 1995, Respondent, without permission, entered Petitioner's home and removed an Ibenez bass electric guitar and R Yamaha effect unit. 1'his is in violation of paragraph 1 of aforementioned Order of Court wherein Respondent is prohibited from entry on to the aforesaid property, except as same may be expressly allowed by Pelitioner and retrieval of personal property therefore such actions have caused great fear and apprehension for Petitioner and the children. c. On July 1, 1995, Respondent proceeded to soll tho above mentioned guitar and effect unit to DCR Music and Sound Shop, 3 Market street, l.umoyne, violation of pal'agraph outlined above. Pennsylvania. Said ad was further In of afurulnenlloflod Oldor of Court a. 5. Hespondent, has wi Ilfully violated the Order of Court dated June 27, 1995. 6, Petilloner requests that Hespondent be held in contempt. 7. Peti lionor requests that Hospondent he requl rod to immediately pay to tho Petitioner tho sum of five hundred twelvo 62/100 dollars ($512.62), togother with the proceeds of the BIlle of musical equipment. 8. Petitioner further- requests reimbursement of all attorneys fees and costs incident to filing this petition lInd tholle proceedings. 9. Petitioner furl/wI' rel\Uests the Hespondent he jailed for said contempt. WIIEIlEFOHE, Petitioner prilYs lIlIs COUI t tu ad1udl,lO the Iluspondent I n contempt of Court. Poll I. t onor I e1luOllts that Ilespondon t he requ j rod to I end t to IWI the t u II ploceoda of tho Bale of guitar and YlIIlJilllII unit tOIJel.hllr with the Bum of five 4 JANE MARIE QUINN, Plaintiff Defendant IN 1'HE COUR1' OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 95-2842 CIVIL TERM IN DIVORCE v. SHAWN E, QUINN, VERIFICATION I, JANE MARIE QUINN, hereby certify that the facts set forth in the foregoing PE'l'I'nON IN CON'fEMPT is true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa, C.S,A. ~ 4904 relating to unsworn falsification to authorities, Dated: l/)-I9~- . /)/ QUINN, ,- JANE MARIE QUINN, PlainU ff IN 1'IIE CQUIl1' 01' COMMON PLEAS CUMUEIlLANO COUNTY, PENNSYLVANIA NO: 95-2042 CIVIL TEIlM v, SHAWN E. QUINN, IN OIVOHCE Defendant Clm'I'H'ICA'I'E OF SEIlVICE I, Uaruoro Sumple-'/lulllvilll, l,squire, do hereby certify that on this dale, I sorved B tnul and correct copy uf the fOICegoing Plaintiff's PWl'l'I'ION 1"011 CON'l'liMP'I', III the auove-cBptioned matter upon tho fol!owllI\l illdJvldual(s) uy fiut class mail, postage prepaid, addroBsed as follows: Shawn IL Quinn 35 S, 10lh Slrool Camp 11111, l'A 17011. PA'l'lW: .;July( I 1995 No. 32317 / -' "'----..- i van, !l:squ ICe 17070-1931 7 LAW O"ICII BARBARA SUMPLE.SULLIVAN .... ...1001 n,ullT NEW CUMBERLAN...., rl::.n,4SYLVANIA '7070.'93' ""ON I 1717''714.144' ,AK '71117'4.'1'0" THI' II A ,..UI CO""IC1' COPY 0' T,HI O"IOINAL JANE MARIE QUINN, Phinti ff IN TilE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 95-2842 CIVIL TERM I N DIVORCE v, SHAWN E, QUINN, Defendant pRDER OF COURT And now this J7~day of June, 1995, upon consideration of Petitioner's Petition to Prevent Dissipation of Marital Property and Exolusive Possession of the Marital home, which PQtition was duly served on the Respondent on June 1, 1995, and after hearing to which the Respondent failed to attend, it is hereby ordered and decreed: 1) Petitioner, Jane M. Quinn, for herself and for the minor children, Teague (DOB 12/13/82) and Fagan (DOB 12/9/85), is hereby awarded exclusive possession of the marital home at 722 Kent Drive, Mechanicsburq, Cumberland County, Pennsylvania, Respondent, Shawn E. Quinn is prohibited from entry on to the aforesaid property except as same may be expressly allowed by Petitioner, A copy of this order shall be provided to the lIamden Township Police Department for enforcement, 2) Respondent, Shawn J;:, Quinn, is specifically prohibited from selling, transferring, alienating, trading or in any other way disposing of or encumbering any marital or singularly tilled property, personal or real, Respondent is specifically prohibited from extending ~he axlsting line of credit which exists through Members First Credit Union on tho marital residence located at 722 Kent Drive, Mechanlcsburg, Pennsylvania. Respondent is further prohibited from creating any additional debt for which the parlios mar become obligated. Respondent is further prohibited from removing from the marital home any items of personal properly. 3) The remaining severance check which Respondent is lo receive from his prior employer, PIIlCO, shall be tendered br PHICO lo Petitioner for her use in paying marital obligalions, including but not limited to, the mortgage. Notice of lhis order shall be promptly delivered to PHICO which is directed to make said check, and any additional checks which may be due to Respondent, payable directly to Petitioner, Jane E. Quinn, In lhe event that said sums are already forwarded by Pill CO prior lo receipl of said order, Respondent is specifically direcled lo remit said check or lhe proceeds of same lo Petilioner for use br Pelitioner lo salisfr marital debls and for her support and the support of lhe children, 4) Pending furlher order lhrough Domestic Relations, Respondent is herebr directly lo remit to the Petitioner from his Unemplorment Compensation the sum of eleven hundred dollars per month ($1100,00) in bi-weekly installments of five hundred fifly ($550.00) to be used for Petitioner's support, the support of the parties' children and payment of the marital debts, Said payments shall be made wilhin twentr-four (24) hours of Respondent's receipt of said funds, RUE COpy FROM ReCOR~nd ~ 'mClllV ~M(6uf I I hllle ur-to set my ~~, Mal 01 &aId C.ourt a\ ~r\ls'e. Pa. 5 , ~ a . BY TilE COURT: l ~ &ffi "8. ~ 'lIe 110 arable Edgar B. B yley '. , , (c0 1-1 f ,~i .. ~ ~ ~ ! ~ I~ ~! . H. j i~ ~ ~~ ~ ~ lG ~ , , . . . . ~ r"; .........1 ... ~ I" '1 il ~ " , ! JANE MARIE QUINN, Plaintiff IN 1'IlE COUR1' OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. CIVIJ, SHAWN E. QUINN, Defendant IN DIVORCE I.. PETITION TO PREVENT DISSIPATION OF MARITAL ASSETS AltD TO RECEIVE EXCLUSIVE POSSESSION OF TilE MARITAL HOME \ 1. Petitioner is JANE MARIE QUINN, an adult individual ~ residi ng with her chi ldren at 722 Kent Dri ve, Mechanicsburg, I Cumberland County, Pennsylvania 17055. 2. Respondent is SIlJlWN E. QUINN, an adult individual residing at 722 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. ], Respondent has had a history of heroine abuse but had kept same in control for over nine (9) years. 4, Over lhe lasl few months, Respondent has relapsed into, said drug use, causing him to be unpredictable and to give little concern for the marital household, lhe Plaintiff or the parties' children, Teague (age 12) and Fagan (age 9), 2 5. Bince Wednesday May 3, 1995, Hespondent has left the marital home for days without advisinQ Petitioner of his whereabouts. Purlng said absence, Hespondent would only return to and enter the marital home at limes during which the Plaintiff and the parties' children were not at home. 6. Heepondent ha. aho withdrawn One Thousand Two Hundred Dollara ($1,200.00) from the parties' home equity line of credit without Petitioner's consenl or knowledQe before Petitioner was able to close same. 7. Ilel(londent recei ves a sevarance check from his past employer and unemployment compensation check. Respondent has ulilized aaid monies fOJ support of his drug habit and not in support of his family. Despite spending those sums received, the check he forwurded to the bank for the family's mortgage payment WaS returned for in8ufficlent funds. 8. Pel1Uoner hss leaned that Hespondent has borrowed in excen of '1,000 0111118 Indlvidul11ly tilled credit. card. 9. Petltlollll/ helleves and therefore avorsthl1tllespondent has exhausted In OMCIlIIIl of $2,000 over the last three weeks to support his heroine habIt. ] 10, It is believed and therefore averred that the Respondent may enter the marital home to take personal items to sell from said property for money in support of his heroine addiction, Respondent had taken a bracelet of Petitioner's valued in excess of $300 but returned same upon confrontation by Petitioner. 11, Petitioner believes that Respondent will attempt to continue to enter the marital home and to dissipate, transfer, alienate or otherwise encumber other marital property or accounts of the parties and create extreme indebtedness for said parties. 12, Petitioner resides in the marital home with the parties' children and the mental and emotional health and welfare of the Petitioner and the children is compromised by allowing Respondent unrestricted access to the marital home which has the result of instilling fear and anxiety in the children because of Respondent's lack of predictability and control resulting from his current addiction. 13. Petitioner has limited employment as an in-home child care provider. lIer income is limited and so is her ability to relocate her children. 14. Section 3502 (c) of the Divorce Code state that "the Court may award during the pendency of the action or otherwise to one or both of the parties the right to reside in the martial 4 Relief and enjoin and restrain Respondent, Shawn Quinn, from encumbering, dissipating, selling or otherwise alienating any marital assets of the parties or otherwise incurring indebtedness, Petitioner further requests the Court grant her and the parties' minor children exclusive possession of the marital home pending further order of Court. Respectfully submitted, ) Dated: May 24, 1995 ... .;:.' L (Barbara S pIe-Sullivan, Esquire 549 Bridge street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court 1.0. 32317 Attorney for Petitioner 6 ~ANE MARIE QUINN, Plaint! rf IN 1'IlE COURT OF COMMON PLEAS CUM8ERLAND COUNTY, PENNSYLVANIA vs. No. CIVIL ~IlAWN E. QUINN, Defendant IN DIVORCE VERIFICATION I, JANE MARIE QUINN, hereby certify that the facts set forth In the foregoing PETITION TO PREVENT DISSIPATION OF MARITAL ASSETS I ; ~nd PETITION FOR EXCLUSIVE POSSESSION OF TilE MARITAL HOME are true I , I rnd correct to the best of my knowledge, information and belief. I ~nderstand that any false statements made herein are subjeot to [ penalties of 18 Pa. C.S,A, ~ 4904 relating to unsworn falsification i ~o authorities. ! bated: I 51,l1J /9.')- , ~2 kL In. 41,~ JA MARIE QUINN JANE MARIE QUINN, Plaintiff IN TilE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO', I, .. I I ~.,. .','1,. .J,~,. 'r<} ~ //Itl _'t -,,,,, SHAWN E. QUINN, I>ofendanl CIVIL ACTION - LAW IN DIVORCE fillrl.('K '1'0 DE.'END ANI> CLAIM R1GHT9 YOU UAVE DE EN 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 lhat if you fail to do so the case may proceed withoul you and a decree of divorce or annulment may be entered againsl you by lhe Court. A judgemenl 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 olher rights importanl to you, including custody and vieitation of your children. When the \lroundli for a divorce Iii indignities or irretrievable breakdown of lhe marrlago, you may requesl marriage counseling. A list of marriage counselors Is available in lhe Domestic Relations Office at the Counly Courlhouso. IF YOU DO NO'I' FILE A CLAIM mil A1,lMONY, DIVISION OF PROPERTY, LAWYER'S nES OR .:XPENSES DEFOR.: A DIVORCE 011 ANNU[,MEN1' IS GRANTED, YOU MAY LOSE 1'UE IIIGlIT 1'0 CLAIM ANY OF TUEM. YOU SUOULD '['AKF; TUl S PAPF;II '['0 YOUR LAWYER A1' ONCIL 1 I' YOU DO NO'I' UAVE A LAWYEII 011 CANNO'I' AFFOHll ONE, GO '['0 OR TELEPHONE 1'UE OF'FICE SE'[' I'OR'I'U D!;;LOW '1'0 FIND 01l'1' WHERE YOU CAN GE1' LEGAL HELP. l.AWYKH IIEFKHHA[. 8KIlVICK COllR'j' AI>MINID'I'RA'I'OR 4th Fhx)r, Cumborland counly Courlhouso Car llal 0, l'U1l11ay \vania 1701 J (717) HO-6:100 JANE MARIE QUINN, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: CIVIL ACTION - LAW IN DIVORCE v, SHAWN E, QUINN, COMPLAINT IN DIVORCE 1, Plaintiff is JANE MARIE QUINN, an adult individual residing at 722 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, 2, Defendant is SHAWN E, QUINN, an adult individual residing at 722 Kent Drive, Mechanicsburg, Cumberland Cnunty, Pennsylvania 17055 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (61 months prior to filing this complaint. 4. The Plaintiff and Defendant were married on April 10, 1982, in New Cumberland, Cumberland County, Pennsylvania. 5, '~ere are two (21 minor children born of this marriage: Teague W. Quinn, born December 13, 1982; and Fagan E. Quinn, born December 9, 1965. 3 r " 6, The parties separated on April 1, 1995, 7, The marriage is irretrievably broken, , B, Neither Plaintiff nor Defendant is in the military or naval service of the United states or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. i I , 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiff's Complaint dre incorporated herein by reference thereto, 11, The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with ~ 3301 of the Pennsylvania Divorce Code. 4 DESERTION 12, The averments in paraQraphs 1 throuQh 11, inclusive of Plaintiff's Complaint are incorporated herein by reference thereto. i.' 13. Defendant willfully and maliciously deserted Plaintiff, the innocent and injured spouse, and has been absent from the habitation of Plaintiff, without a reasonable cause. WHEREFORE, Plaintiff requests entry of a divorce decree in her \ favor in accordance the Pennsylvania Divorce Code. INDIGNI1'JK8 14. The averments in paragraphs 1 lhrough 13, inclusive of Plaintiff's Complaint are incorporated herein by reference thereto, 15. Plaintiff is the innocent and injured party, and Defendant has offered such indignities to the person of the Plaintiff and has been mentally cruel to her so as to make her life burdensome and her condition intolerable, in viollllion of lhe marriage vows and of tho laws of the Commonwealth. WIlEHEFORE, Plaintiff requests IIllu Coult to olltel a decree in divorce in accordance with the Pennsylvania llivorco Code. 5 COUNT II EOUITABLB DISTRIBUTION 16, The averments in paragraphs 1 through 15 of Plaintiff's Complaint are incorporaled herein by reference thereto. 17, The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors, WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance with Section 401(d) of lhe Pennsylvania Divorce Code. COUNT II I SUPPORT. ALIMONY PENDENTE LITE AND ALIMONY 18, The averments in paragraphs 1 through 17, inclusive, of Plaintiff's Complaint are incorporated herein by reference thereto, 19. Plaintiff requires reasonable support to adequately sustain herself with the standard of living established during the marriage. WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lile. COUNT 1 V A1~~RNEY'S FEES AND COSTS 20. 'I'ho averments in paragraphs 1 lhrough 19, inclusive, of , Plainliff'a Complainl are incorporaled herein by reference thereto. 6 21. Plaintiff in unablo to sustain horsolf durinQ the course of this litiQation and has omployod Barbara Bumple-Bullivan, Esqui re as counsol, but Is unablo to I'IIY tho neceesary and reasonable attornoy's foos for said counsol, and tho necessary and reasonable costs and oxponsos. WHEREFORE, Plaintiff roquosts an IIward of counsel's fees and expenses. /lil/EREFORE, I'lolnl1 rr, .JAN~: HARlE QUINN, proys this Honorable Court to onter judQmont: A. Awardiny Plaintiff a doc roo In divorco; B. Awarding Plainl1 rr support, al imony and alimony pendente 11 to; C, AwardinQ Plalnl1rr counsol fuus, costs and expenses; 0, Equitably dlstrlbul1ny lho marital proparty; and reasollllhlu. tho Court 900ms just and ,/ //} ,~(.f:;~I:';;-; ,..';i,; Attorney for I'laintiff 549 BrldQo Btreet New Cumberland, PA 17070-1931 (717) 774-1445 Supremo Court 1.0. No. 32317 E, AwardlnQ othor rulluf IlS Dated: HaytY, 1995 7 .--' . . ------. JANE MARIE QUINN, Plainli!! v. IN TilE COURT OF COMMON PLEAS CUMI3EIlLANO COUNTY, PENNSYLVANIA NO: 95-2842 CIVIL TERM IN DIVOIlCE SIIAWN E, QUINN, llofendanl ^PPIllAVIT OF SERVICE I, '1'1I0MA:l O. EMI';llICK, PaI'alegal to Barbara Sumple-Sullivan, Esqui re, do hurnhy curU f y lhat I served upon the above named Defendant, Ilhown I,. QuInn, a lrue and correct copy of Divorce Complaintl Onlol of Courl daled May 30, 1995 and the Petition to Prevenl lliHSII'Il11on of Marilal Assets and to Receive Exclusive Possession or thu Marital lIome by personally handing same to the Defendanl in the monner indicated below. Dalel Timel I'loce: .Juno 1, 1995 4: 10 p.m, Carllnlo 1I0npilal, Carlisle, P^ 17013 Datud: .Juno 2, 1995 I .'. \, 1'IiOMAS (f. (EMERICK I'ENNSYINANIA COMMONWEAl/I'll O~' : SS. COllN'I'Y OP CllMIlElll.ANll On this, the 1st day of June, 1995 before me, a Notary Public, lhe ullllorsl'Jned officer, personally appeared Thomas G, Emorick to ho lho pOlson whose name is subscribed to the within instrument, /lnd acknuwledged that he executed the foregoing Divorce Complaint; Ordor of CourL daled May 30, 1995 and Lho Petition to Prevent 1llllllll,aUon of Marital Assets and to Ileceive Exclusive Possession of lho MaCllal 1I0me for the purposes contained therein. IN W 1'NESS ("fIlEOI" ... 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