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Home My WebLink About95-06594 . ., 0- f e... '~ , &: 'p! J '-:I- 0:- lD .:J . ~ CYNTHIA L. STRUPP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION. LAW TIMOTHY H. STRUPP, Defendant NO. 95-6594 CIVIL TERM ORDER OF COURT AND NOW, this 27th day of October, 1998, upon consideration of Plain tilT's Petition, It is ordered that (I) a rule is issued upon Defendant to show cause, if any he has, why Plaintiff is not entitled to the relief requested; (2) Defendant shall file an answer to the petition within 21 days of this date; (3) the Petition shall be decided under Pa. R.C.P. 206.7; (4) depositions shall be completed within 35 days of this date; (5) argument shall be held on Friday, February 12, 1999, at 1:45 p.m., in Courtroom No. I, Cumberland County Courthouse, Carlisle, Pennsylvania; and (6) notice of the entry of this order shall be provided to all parties by Plaintiff. BY THE COURT, ,_~~ ..:,"<.. h.'"-.1:~.~'-''' Fllf:D-{)fFiCE OF T/-'~ Pt70Tf!CN:JiAAY 98DCT29 AI/I/:/,4 CUM3EFiU','\iD COUNTY PENNSy/'\W11A .. . :,..:.....;...<,:. ...........,.--- <>. \l- . .... I'l\ ~ '1 } Marcus A. McKnight, III, Esq. 60 West Pomfret Street Carlisle, PA 17013 Attomey for Plaintiff Anne M. Shepard, Esq. 200 North Hanover Street Carlisle, PA 17013 Attomey for Defendant :rc ''!<'l<''~',"..'.':'''''' .' ""~"'~:":l."'.""':;';;'-"<"-'<''' .-.i..y......'...._.....:. , CYNTHIA L. STRUPP, Peddoner : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION . LAW 95-6594 CIVIL TERM TIMOTHY H. STRUPP, Respondent IN DIVORCE RULE TO SHOW CAUSE AND NOW, this _ day of October, 1998, a rule to show cause why this matter should not be kept open as requested by the Petitioner, Cynthia L, Strupp, on the Cumberland County Civil Docket, is hereby issued to the defendant, Timothy H. Strupp, THIS rule is returnable in days from the date of service, BY THE COURT, J. CYNTHIA L. STRUPP, Petitioner : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-6594 CIVIL TERM TIMOTHY H. STRUPP, Relpondent IN DIVORCE PETITION AND NOW, comes the petitioner, Cynthia L. Strupp, by and through her attorneys, Irwin, McKnight & Hughes, and files this Petition, making the following statement; 1. The petitioner in this matter is Cynthia L. Strupp, and the respondent is Timothy H. Strupp. 2, At 95-6594 Civil in the Court of Common Pless of Cumberland County, an action was filed by the petitioner against the respondent by means of a Complaint in Divorce. 3, Since the time of filing of the Complaint, the parties have attempted reconciliation, but the petitioner seeks the completion of the divorce and the resolution of the equitable distribution as well as alimony and support issues. ,.~~;.;,"'-~";-""";""",~; '.,...":..,."....1>""",..'""^':.._...,_.....-........~..~,._., ..- , 4. The petitioner seeks that this case be kept active. WHEREFORE, the petitioner, Cynthia L. Strupp, respeclli.dly requests that this matter not be purged from the Civil Docket list but remain active, Respectf\\lly submitted, IRWIN, McKNIGHT & HUGHES Mar sA.M Attorney for Pe Cynthia L. Strupp 60 West Pomfret Street Carllsle, Pennsylvania 17013-3222 717-249-2353 Supreme Court 1.0. No. 25476 By: Date: October 26, 1998 ......( '''t' ,.....,..., . . CYNTHIA L. STRUPP, Peddoner : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-6594 CIVIL TERM TIMOTHY B. STRUPP, Reapondent . . IN DIVORCE CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that on this date a true and correct copy of the Rule to Show Cause and Petition was served by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, upon the following; Anne M. Shepard, Esquire Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 Attorney for Respondent Timothy H. Strupp IRWIN, McKNIGHT & HUGHES By; Marcu A. Me 60 West Pomfret S Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Date: October 26, 1998 '-;."'~",,,"" . . ., , CYNTHIA L. STRUPP, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. , , : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACfION . LAW . . : 9~CIVlL TERM TIMOTHY H, STRUPP, Defendant . , . , IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth In the foUowing 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 property or other rights Important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE mGHT 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 1 Courthouse Sq uare, 4th Floor Carlisle, Pennsylvania 17013 717.249.6200 .. .--",' ..,..... --" , I IN THE COURT OF COMMON PLEAS OF CYNTHIA L STUPP, Plaintiff . . : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACflON . LAW 95- CIVIL TERM v, TIMOTHY B. STRUPP, Defendant IN DIVORCE COMPLAINT R! DIVORCE PURSUANT TO SECTION 3301fs} OF THE DIVORCE CODE NOW comes the plaintiff, Cynthia L. Strupp, by her attorney, Marcus A. McKnight. Ill, Esquire, and files this complaint in divorce against the defendant, Curtis Lee Grant. representing as follows: 1, The plaintiff is Cynthia L. Strupp, an adult individual residing at 1935 Spring Road, Carlisle, Cumberland County, PeMsylvania 17013. 2. The defendant is Timothy H. Strupp, an adult individual residing at 85 Cherry Lane, Carlisle, Cumberland County, Pennsylvania 17013. 3, The plaintift' has been a resident of the Commonwealth of PeMsylvania at least six months prior to the filing of this action in divorce, ---'~_..-...'~""""\\~~"'i;"'~'>':0T-"'...~_""~"""..'- ..-..,,-. .. 60 Wat Po t Street Carlisle, Pennsylvania 17013 (717) 249.2353 Supreme Court lD No. 25476 4. The plalntift'and defendant were married on July 21, 1984 in Carllsle, Pennsylvania. S. Pursuant to tho Divorce Code, Sec1ion 3301(c), the plaintiff avers as the grounds upon whlch thls action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties, I verifY that the facts contained herein are true and correct. I understand that false statements herein made are subjec1 to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. 1I/.6lI, ,3 .1995 ~,1S(~ CY TRIA L. STRUPP, Plain Iff - ~.. ... -f '_...!..,i...,t:.'.,.c,..'~"'''': _,o"_r',. c_._, -...... ,,-., " CYNTHIA L. STRUPP, Plaintiff : IN THE COURT OF COMMON PLEAS OF . . : CUMBERLAND COUNTY, PENNSYLVANIA . , y, CIVIL ACTION . LAW 9S. CIVIL TERM IN DIVORCE . , TIMOHTY B, STRUPP, Derendant . . , . PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2, I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verilY that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities, 11A1f '3 ~i1'~t NTBIA L. STRUPP, Plaintiff .1995 '"""-....'...."..~. ,'" ,'., -....., -,'~ ""--~-"""--""~.'--"---""""~~w,;.;~"""'..'.d';-'.-,,,,,...,,>:..-.,,~ --.'" . ,- ~..- '.'o:,.:r,;+"..: '-::~''l;~'-l'_''; _._.-4>_ -..~..~ _. _ ...~.'.~ ,~,,"" ,~"'~_' ,'$. . _'. _. . _'.', - ~ . '.. a: "" _ F A ~," , ~.' > .. >. _, _ ' _ ~", , .." '" -.L ' t' _ _ "",' -.; _, ,","' ~ " ~ , .. ~-"--" - "- i . . " CYNTHIA L, STRUPP, t IN THE COURT OF COMMON PLEAS OF plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : TIMOTHY H. STRUPP, : Defendant , No. 95-6594 CIVIL TERM . ORDER OF COURT AND NOW, this 12th day of February, 1999, upon consideration of the plaintiff's Petition to strike this case from the purge list, and plaintiff's counsel, Marcus A. Mcxnight, III, Esquire, having appeared in court for the argument scheduled on the matter, and Defendant having not appeared either personally or through counsel for the argument, and having failed to file an answer to the Petition, the Plaintiff's Petition to strike the case from the purge list is granted, the Rule issued on the Petition on October 27, 1998, is made absolute, the case is stricken from the purge list, and the matter shall continue as an active case. By the Court, MARCUS A. McKNIGHT, III, 60 West Pomfret Street Carlisle, PA 17013 For the plaintiff ESQUIRE ~ .... \JJ -r, ,.., :;J ro lj;:n f~' I <:0 ~f~~ -<. . t:~c; ;1 :1( ~~; r-:. ;:~1~ '-\,J 6'''' 'J>(. ,. ca ~ -~ :11 ~ (7' ANNE M. SHEPARD, ESQUIRE 200 North Hanover Street CarliSle, PA 17013 For the Defendant Court Administrator _ ~~~ .:l./,q/a.'l, ;5,('. wcy } tiLe 0/[. p. J. CYNTHIA L, STRUPP, Plaintiff vs. : IN THE COURT OF OMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW TIMOTHY H. STRUPP, Defendant : NO, 95-6594 CIVIL TERM ORDER OF COURT AND RULE TO SHOW CAUSE AND NOW, this t. K day of -111 ZJ c..~ ' 1999, upon presentation and consideration of the within Petition a Rule is hereby issued upon the Defendant. Timothy H. Strupp, to show cause, if any he has, as to why Anne M. Shepard, Esquire. should not be permitted to withdraw as his legal counsel in the above-captioned action, Rule returnable -1f. days aller service by first class mail, postage prepaid to the last known address of the Defendant. BY THE COURT, CYNTHIA L, STRUPP, Plaintiff : IN THE COURT OF OMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW TIMOTHY H, STRUPP, Defendant : NO, 95-6594 CIVIL TERM PETITION TO WITHDRAW AS LEGAL COUNSEL AND NOW, comes Petitioner, Anne M. Shepard, Esquire, attorney of record for the above-named Defendant and petitions the Court as follows: ] , Your Petitioner is attorney of record for the above-named Defendant, Timothy H. Strupp, 2, Despite repeated requests for cooperation and responses to various issues that have arisen in this case, Defendant has failed and refused to respond to Petitioner. 3, Despite requests to provide a retainer to be applied to for services as they are rendered in this matter, Defendant has failed to provide a retainer and has failed to communicate with Petitioner or her office relative to this matter. 4, Petitioner is no longer employed with the law firm of Griffie & Associates at 200 North Hanover Street, Carlisle, Pennsylvania. but rather is employed by the law firm of Kaminski & Hawbaker at 221 Lincoln Way East. Chambersburg, Pennsylvania. 5. Upon the information received, Petitioner believes and, therefore, avers that the law linn of her prior employment. Griffie & Associates, has not been able to secure a response from Mr. Strupp relative to these matters either, WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon the Defendant to Show Cause, if an~' he has, as to why Petitioner should not be permitted to withdraw as his attorney, %GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 DATE1t;x~ /f91 VERIFICATION 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. ~...' .....,........-. - ,.. .-'.....,- . ;'-',,'..- iT. CO': (:; ;..-: M .- '") -,~ hr' Q~ l ..;. ::l: (..>.... r '~.' c.. ... ~' r:;1;'-J ( , N ..~ I' ::5' I: ~. I _I, C'-' l5ffi u: ,. :L _4 tnfJ... ,- :c a '1.. 0'\ U 0'\ CYNTHIA L. STRUPP, Plaintiff ; IN THE COURT OF OMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA VI. . . ; CIVIL ACTION - LAW TlM011lY K STRUPP, Defendant . . : NO. 95-6594 CIVIL TERM ORDER OF COURT AND NOW, this ~ clay of ~ 1999, upon presentation and consideration of the within Ptltition, the Rule previously entered in this matter on March 6, 1999 I. hereby made absolute and Anne M. Shepard, Esquire I. hereby permltted to withdraw u 1ep1 counsel for the above-named Defendant, Timothy H. Strupp. BY THE COURT, 1. ~~" ~~tt-. ~ff?;r17()/3 'yn~,4 . ;n::... ~71l-1 ~f . ~O It;. p~ 'P. ~ J plJ- J 7tJ/S R ~-.: ~'~6 r:t'-:! j~;;::! ":'c ... ~~\j c';c j;';{":! :.--:'" ;~ l..::l .", 0 ::-' '.11 =;; . :_~j '''' r:\2} t'-.) -..h, "'0 ~_) l :r... :;-j~rJ ::~ ;~i:iJ - -.-<) r:? ~ ,If I ~.. ~ ~ 1~~!7J: ~,~/7~/3 e..oa ^,~ 4-J,,-\/qcl. '''<l' ,. c ,:> ..>4- . . . cYNTHIA L. STRUPP. Plaintift' : IN TIlE COURT OF OMMON pLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA : CIVIL ACTION. LAW VI, TIMOTHY H. STRUPP, Defendant : NO. 95-6594 CIVIL TERM PETITION TO MAKE RULE ABSOLUTE AND NOW, COlI1CI Petitioner. Anne M. Shepard. Esquilll, attorney of IllCDrd for the aIJoyc-oamcd DcfcovIant 8IId pctitiOlll the Court u follows: 1. Your petitioner filed a Petition to withdraw u counsel in the abovc<aPtioncd action on March 2, 1999 which resulted in the entry of an Order of Court 8IId Rule to Show Cause dated March 6, 1999, a c:opy of said Petition 8IId Order of Court being atlA"~ bclllto 8IId incorporated herein by Illfcreocc u Exhibit "A." 2. Pursuant to the aforesaid Order, Defendant. Timothy H, Strupp was served by first class mail, postage pre-paid by corrcspondcncc dated March IS, 1999. 3. MOIll than 1S days bas passed since service ofthc aforesaid Order of Court 8IId Rule to Show Cause 8IId lID Answer bas been filed. WHEREFORE, Petitioner IIllluests your Honorable Court to make the aforcmcntioncd Rule to Show Cause absolute thereby pennitting your Petitioner to withdraw as counsel for the aIJoyc-oamcd Defendant, Respectfully submitted by, !21Al Lfft b/ , Anne M. Shepard. iM Attorney for Defendant 221 Lincoln Way East Chambersburg, PA \7201 (717) 263-4400 (800) 347-S5S2 VERIFICATION I VB1lIPY mAT nIB STATEMENTS MADB IN nIB FOREGOING DOCUMENT ARB TRUB AND CORRECT. I UNDERSTAND mAT FALSB STATEMENTS HEREIN MADB ARB SUBJECT TO nIB PENALTIES OF 18 PAC,S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AunlORlTlBS. DATB:~F-J Jj ftl'l9 ~fcJ ~~~ Anne M. Shep B , ,"' ....< . ;>; r ...-,w__...._. ._,....b__._..._. _._.--;.'............,,_,--. _<n.C '. CYNTHIA L. STRUPP, Plaintiff : IN THE COURT OF OMMON PLEAS OF ; CUMBERLAND COUNTY. PENNSYLVANIA VI. . : CIVIL ACTION . LAW TIMOTHY H. STRUPP, Defer!"-nt . ; NO. 95-6594 CIVIL TERM 9RDER OF COURT AND RYLE TO S1IOW CAUSE AND NOW, this ,tL day of --n, ~ . 1999, upoo prCJ> .1.1:00 IIld consideration ofthc within Petition a Rule is hereby issued upon the Defendant, lllDOthy H. Strupp, to show cause, if lID)' he bas, a.:: to why Anne M. Shepard, Esquire, should not be permitted to withdraw as his legal counsel in the above-captioned action. Rule returnable ...1:L. days after service by first class mail. postage prepaid to the last known address of the Defendant. BY THE COURT, 1$ / J..JS' .~/iJ tL. au. , (J J. EXHIBIT "A" , , '. CYNTHIA L. STRUPP, Plaintilf IN THE COURT OF OMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVIL ACTION. LAW vs. n G -cQ "". ;:;::, cJj~ -< .... PETITlONTOWIIHURAW ASLEGALCOUN$liL f2':::::! ":"';(-, - -Cl AND NOW, comes Petitioner, Anne M Shepard, Esquire, attorney oCfiMrd ~r -< r" the above-named Defendant and petitions the Court as follows: TIMOTHY H. STRUPP, Defendant : NO. 95-6594 CIVIL TERM 1. Your Petitioner is attorney oC record Cor the above-named Defendant, TlIDothy H. Strupp. 2, Despite repeated requests for cooperation and responses to various issues that have arisen in this case, Defendant has Wled and refused to respond to Petitioner. 3, Despite requests to provide a retainer to be applied to for services as they are rendered in this matter, Defendant has failed to provide a retainer and has Wled to communicate with Petitioner or her office relative to this malter, 4, Petitioner is no longer employed with the law firm of Griffie & Associates at 200 North Hanover Street, Carlisle. Pennsylvania, but rather is employed by the law firm of Kaminski & Hawbaker at 221 Lincoln Way East. Chambersburg. Pennsylvania. 5. Upon the infonnation received. Petitioner believes and, therefore, avers that the law firm of her prior employment. Griffie & Associates. has not been able to secure a response from ~[r. Strupp relative to these matters either, <:J ~ ~ ,- ~ , N Sl -:l .~~;I ._:-, ..~- ...- ~Q ~~ am :;l :l1 .... '. WHEREFORE, Petitioner requests your Honorable Coun to enter a Rule upon the Defendant to Show Cause, if any he has, as to why Petitioner should not be permined to withdraw as his anomey. %GRIFFlE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 _re": ......" ":>'",""~".~:t'. .. j'~~.>~ .'7"''''';''':.'''' -- '--.'.,' ". ,<....<.i\~.- ~.:>.;:f:F!:'<:'1F':t',.. f.-. ..,....... ,....;. ~ .- " 1 ~ VERIFlCA nON I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING DOCUMENT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AunlORIl'lES. DATE-;JJ-d?r;; jtftj1 ~ co ~ to? If c:..j 7. :J (..)$ ~ COo.J:;.' Q.., CJ,='; ."'- it C") ~s (,J - ., ? -LI.: ~ .'j -.. L.~ i_!jtfj f- 1."",- -::: .,;,: It 0\ d 0\ Respectfully submitted, va. ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW CYNTHIA L. STRUPP, Plaintiff TIMOTHY H. STRUPP, Defendant : NO. 95-6594 CIVIL TERM : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw my appearance previously entered on behalf of the above- captioned action pursuant to the Court's Order of April 16, 1999, Dat~ '1)1Icnr j \ I ..::~.~;..., ~ \.C, ~ u, i~ .. -'<1" n M i3~> Ul.., O~ <.;.. :C .~ fF'" 0.. ,":):-:i (~r~. "-5= , <.. r- :'!;~ fi" ifl~ 1I ~j ~ ~ LC l Ll.-11 n:.lo... .'- X '"" 1- ~ u.. G"\ a co G"\