HomeMy WebLinkAbout96-00818
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LAW OFFICES
BARBARA SUMPLG-SULLIVAN
, n•lu n1uwll•. N7•tunsr
NNW IN I11!n LAND, PliNNNYINANIA 1717040111 ,
PIIONN (717)
77.1•I (at1
PAX (171 n•1.7nnn
1
May 22, 1996
I ,
The Honorable Edgar B. Bayley
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
I
Ret Riordan v. Riordan
No. 96.818 / Cumberland County
Dear Judge Bayley:
The parties to the above-captioned case have reached a settlement of the action and are
in the process of reducing same to writing. This matter has been scheduled before you on May
30, 1996 at 1:45 p.m, In light of the settlement, a hearing will not be required, We hope to
have the Stipulation to you within the next few weeks for your signature,
Thank you for your consideration of this case.
Very y /Yo u
Barbara Sumple-Sullivan
1
BSS/se (w)
cc; Samuel Andes, Esquire
Michael Riordan
I 1 1
II I
,
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Nl?t??.?I S K(fL14%Plaintiff
V
(ir P(AP11
tIN THE COURT OF COMMON PLEAS OF
(CUMBERLAND COUNTY, PENNSYLVANIA
t
tCIVIL ACTION - LAW
t
:NO.?i? blb CIVIL 19
:CUSTODY/VISITATION
ORDER OF COURT
AND NOW, this Fc(date)y (I6 , upon consideration of the
attached complaint, it is hereby directed that the parties and
their respective counsel appear before f1' cl... t L &.. s ,
the conci r, at _3? F1 5 . IS-1k 51-1, I .r
on the day of ,iJ 19 (, at
M., for a Prehearing Custody Conference. At such conference,
an effort will be made to resolve the issues in dispute; 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. Either
party may bring the child who is the subject of this custody
action to the conference, but the child/children's attendance is
not mandatory. Failure to appear at the conference may provide
grounds for entry of a temporary or permanent order.
FOR THE COURT:
By: llt?
Custody Condiliator
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.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717)240-6200
1
J. RIORDAN,
Plaintiff
V.
J. RIORDAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, ,1j CIVIL, IN DIVORCE/CUSTODY
AND NOW, this _ day of , 1996, upon consideration of the
hed DIVORCE AND CUSTODY COMPLAINT, it is hereby directed that all parties and
counsel shall appear before the conciliator, , Esquire, at
on the day of , 1996 at
for a Pre-hearing Custody Conference,
BY THE COURT,
J. RIORDAN,
Plaintiff
V,
IFER J. RIORDAN,
Defendant
IN TIIE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, CIVIL,
IN DIVORCE/CUSTODY
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COUR'I', if you wish to defend against ;he claims set
th in the following pages, you must take prompt action. You are warned that if you foil to
so the case may proceed without you and a decree of divorce or annulment may be entered
iinst you by the Court. A judgement may also be entered against you for any other claim or
ief requested in these papers by the Plaintiff. You may lose money or property or other rights
portant to you, including custody and visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown of the marriage,
may request marriage counseling. A list of marriage counselors is available in the Domestic
Lions Office at the County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
.ANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
3 OFFICE SET FORTH BELOW '1'O FIND OUT WHERE YOU CAN GET LEGAL
Court Administrator,
Cumberland County Courthouse, 4th Floor
I Courthouse Square
Carlisle, PA 17013.3387
Telephone No. (717) 240.6200
J, RIORDAN.
Plaintiff
V.
J. RIORDAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, CIVIL:
,
:
: IN DIVORCE/CUSTODY
AFFIDAVIT REGARDING CO NS IM
1. 1 have been advised of the availability of marriage counseling and understand that
may request that the Court require that my spouse and I participate in counseling.
2, 1 understand that the Court maintains a list of marriage counselors in the Domestic
office, which list is available to me upon request.
3. Being so advised, I do not require that the Court require that my spouse and I
)ate in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S
relating to unsworn falsification to authorities.
TEt OS re"VIN 199'6 "U /. Lo
MICHAEL J. RIORDAN, Plaintiff
4EL J. RIORDAN, IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
c
V. : NO, CIVIL:
FER J. RIORDAN,
Defendant : IN DIVORCE/CUSTODY
11 Plaintiff Is Michael J. Riordan, residing at 1101 Dry Powder Circle,
, Cumberland County, Pennsylvania 17055.
2. Defendant is Jennifer J. Riordan, residing at Road k5; Box 101, Selinsgrove,
County, Pennsylvania 17870.
3. ' Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for
least six (6) months prior to filing this Complaint.
4. The Plaintiff and Defendant were married on March 16, 1991.
5. There are two (2) minor children born of this marriage: Olivia J. Riordan, born
27, 1991, and Savanah E. Riordan, born December 5, 1993.
6. The parties separated on November 13, 1995.
iii
7.' There have been no prior actions for divorce or annulment between the parties,
g. The marriage is (retrievably broken.
9. Plaintiff has been advised that counseling is available and that Plaintiff may have
right to request that the Court require the parties to participate in counseling.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in accordance
Section 3301 of the Pennsylvania Divorce Code.
10. Paragraphs 1 through 9 of the divorce are incorporated herein by reference.
11. Plaintiff seeks shared legal and temporary physical custody of the following
` PRESENT RESIDENCE
J, Riordan Road #5; Box 101, Selinsgrove,
Pennsylvania 17870.
E. Riordan Road #.5; Box 101, Selinsgrove,
Pennsylvania 17870.
The children were not born out of wedlock
UP
August 27, 1991
Depember 5, 1993
3
The children have resided for the past five (5) years with the following persons at the
addresses,
tnifer J, Riordan Road #5, Box 101
ivia J. Riordan Selinsgrove, PA, 17870
vanah E. Riordan
act J. Riordan 1103 Dry Powder Circle
fer J, Riordan Mechanicsburg, PA 17055
a J. Riordan
iah E. Riordan
:hael J. Riordan 195•B South Oak Drive
nifer J. Riordan Mechanicsburg, PA 17055
via J. Riordan
,anah E. Riordan
I J. Riordan 1143-F School Avenue
r J. Riordan Mechanicsburg, PA 17055
J. Riordan
h E. Riordan
1 :?j Il xv
November 14, 1995 to
Present
July 17, 1995 to
November 13, 1995
March 1994 to
July 11, 1995
January 1992 to
March 1994
The mother of the children is Defendant, Jennifer J. Riordan, currently residing at
#5, Box 101, Selinsgrove, Snyder County, Pennsylvania 17870.
The father of the children is Plaintiff, Michael J. Riordan, currently residing at 1103 Dry
Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055,
12. The relationship of the Plaintiff to that of the children is that of father. The
currently resides with the following persons:
4
NAKE
AEL J, Riordan
D, Riordan
:md Dumas
RELATIONSHIP
Self
Mother
Mother's Boyfriend
13, The relationship of the Defendant to the children is that of mother, The
ant currently resides with the following persons;
NAME
fer J. Riordan RELATIONSHIP
Self
a J. Riordan Child
nah E. Riordan Child
Maurer Mother
Maurer Father
th Maurer Brother
14, Plaintiff has not participated as a party or a witness, or in another capacity, in
litigation conceming the custody of the children in this or another court,
The Plaintiff has no information of a custody proceeding concerning the children
ag in a court of this Commonwealth.
Plaintiff does not know of a person not a party to the proceedings who has
:al custody of the children or claims to have custody or visitation rights with respect to the
5
15, The best Interest and permanent welfare of the children will be served by grunting
relief requested because;
a) The father desires to maintain a constant and loving relationship with his children;
b) Father is able to provide a stable, loving environment for the children while in
his custody; and
c) Mother has acted to deny father access to the children.
16, Each parent whose parental rights to the children has not been terminated and the
person who has physical custody of the children has been named as a party to this action,
WHEREFORE, the Plaintiff requests the Court to grant to the Plaintiff shared legal and
emporary physical custody of the children.
Barbara Sumple•Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070.1931
(717) 774-1445
Supreme Court I.D. 32317
,? I I
6
J. RIORDAN- t IN THE COURT OF COMMON PLEAS
Plaintiff ; CUMBERLAND COUNTY, PENNSYLVANIA
NO, CIVIL:
V. '
t
J. RIORDAN,
Defendant IN DIVORCE/CUSTODY
I, MICHAEL J. RIORDAN, hereby certify that the facts set forth in the
Dregoing COMPLAINT IN DIVORCE AND CUSTODY are true and correct to the best of
ty knowledge, Information and belief. I understand that any false statements made herein are
object to penalties of 18 Pa.C.S, §4904 relating to unsworn falsification to authorities,
l ?
dijkA&MY-afl, MICHA J. RIORDAN
I
7
J. RIORDAN, ; IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V, ; NO, 96-818 Civil Term
J, RIORDAN,
Defendant ; IN DIVORCE/CUSTODY
AFFIDAVIT OF S uV,Ct;
1, Barbara Sumple-SullIvan, ESQUIRE, do hereby certify that I served a copy of the
omPlalnt In Divorce in the above-captioned matter by United States Mail, Restricted Delivery,
eriffied No. P 377 421 706, Return Receipt Requested, on the above-named Defendant,
ennifer J, Riordan, on February 23, 1996, at Defendant's last known address; Road #5 Box
101, Selinsgrove, Pennsylvania, 17870. The original rc •cipt and return receipt card number
(Certified No. P 377 421 706 are attached hereto evidencing receipt on February 24, 1996,
ated; Februp_r„ ?7 '1998 L??
Barbara Sumplc-Sullivan, Esqufre?
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ID # 32317
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EXHIBIT "All
Gahr Sholder
BY; Richard A. Rehr.
Identification I10.1 17683
Attorney fort plaintiff
JENNIFER J. RIORDAN,
Plaintiff
Vs.
MICHAEL J. RIORDAN,
Defendant
17U W, Thliitn sl'RkE'I'
WILLIAM51'010', I'A 17701
1717) 111-9177
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS SECTION
DIVORCE/CUSTODY
NO, 96-818
ENTRY OF APPEARANCE
Please enter our appearance as attorneys for Jennifer J.
Riordan, Plaintiff, in the above-captioned case.
1
GAHR & SHOLDER
i00??
I
Richard A. Gahr
Attorneys for Plaintiff
I.D. #17683
270 West Third Street
Williamsport, PA 17701-6428
Dated; February 29, 1996
pct Barbara,Sumple-Sullivan, Esquire
File
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. APR 11 l ]9G?.?,
MICHAEL J. RIORDAN,
Plaintiff
vs.
JENNIFER J. RIORDAN,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION • LAW
NO. 96-818 CIVIL TERM
IN DIVORCE/CUSTODY
AND NOW, this I-l day of (?h, L 1996, upon receipt of
the Conciliator's Report, it appearing that the parties have agreed to some of the
terms regarding custody of their minor children, but that they require a hearing to
resolve all of the issues, It is hereby ordered and directed as follows:
A hearing is scheduled for the _ ?? ? ti day of
1996, at _ i O'clock ,m. in Court
U
Room Number of the Cumberland County Court House, Carlisle,
Pennsylvania. The hearing will be restricted to determine the periods
of partial custody and visitation with the Father, including vacation
time. Counsel shall provide a list of witnesses and their proposed
resolution of the matter to each other and the Court ten (10) days
prior to the hearing.
Pending said hearing, it is ordered and directed as follows:
1. The parties shall share legal custody of their minor children,
Olivia J. Riordan, d.o.b. 27 August 1991, and Savanah E. Riordan,
d.o.b. 5 December 1993.
APR 1119Jf?
2, Mother will have primary physical custody of the minor
children subject to periods of partial custody and visitation with Father
as determined by the Court after hearing,
3. The parties shall alternate the following major holidays; New
Year's Day, Memorial Day, Fourth of July, and Labor Day, Father will
have New Year's Day and Fourth of July in even-numbered years and
will have Memorial Day and Labor Day in odd-numbered years, while
Mother will have New Year's Day and Fourth of July in odd-numbered
years and Memorial Day and Labor Day in even-numbered years.
These periods of partial custody will be from 9:00 a,m. until 7:00
p.m., except that if they occur on a regular weekend period of custody
to be determined with the Father, then he may extend the custody
weekend to Include that day and return the children at 7:00 p.m. on
that holiday,
4, The Easter holiday shall be broken into two segments which
shall be alternated. Segment A shall occur from Saturday at 3:00
P.m; until Easter Sunday at 2;00 p.m, Segment B shall occur from
Easter Sunday at 2:00 p,m. until 8:00 p.m. In 1996 and all even- I1
numbered years thereafter, Mother shall have Segment A and Father
shall have Segment B. In 1997 and all odd-numbered years thereafter,
Father will have Segment A and Mother will have Segment B.
j;
Iii
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6. The Thanksgiving holiday will be broken Into two segments
which shall be alternated. Segment A shall occur from Wednesday at
6:00 p,m, until Thanksgiving Day at 3:00 p.m. Segment B shall occur
from Thanksgiving Day at 3:00 p,m, until Friday at 7:00 p.m. In 1996
and all even-numbered years thereafter, Father will have Segment A and
Mother will have Segment B. In 1997 and all odd-numbered years
thereafter, Mother will have Segment A and Father will have Segment B
6• The Christmas holiday will be broken into two segments
which shall be alternated. Segment A shall occur from 12:00 noon on
Christmas Eve until 12:00 noon on Christmas Day. Segment B shall
occur from 12:00 noon on Christmas Day until 12:00 noon on 26
December. In 1996 and all even-numbered years thereafter, Father
shall have Segment A and Mother shall have Segment B, while in
1997 and all odd-numbered years thereafter, Mother shall have
Segment A and Father shall have Segment B.
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
Samuel L. Andes, Esquire
Attorney for Defendant
C!,.JIA?o. (YwO-UItl yI tOTr'4h .
mlb
MICHAEL J, RIORDAN,
Plaintiff
vs.
JENNIFER J. RIORDAN,
Defendant
IN DIVORCE/CUSTODY
JUDGE PREVIOUSLY ASSIGNED: None (No Judicial Conflicts)
CUSTODY CONCILIATION CONFEBENC?F SUM gEPOgT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1916.3-8(b1, the undersigned Custody Conciliator submits the
following report:
1 . The pertinent information concerning the children who are the subject of
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO, 96-818 CIVIL TERM
this litigation is as follows:
Olivia J. Riordan
Savanah E. Riordan
27 August 1991
6 December 1993
CURRENTLY IN
CUSTODY OF
Defendant/Mother
DefendanUMother
2. A Conciliation Conference was held on 14 March 1996, and the following
individuals were present: the Plaintiff and his attorney, Barbara Sumple-Sullivan,
Esquire; the Defendant appeared with her attorney, Samuel L. Andes, Esquire.
3. Items resolved by agreement: See attached Order.
1
4, Issues yet to be resolved; The partial custody and vieltation schedule
with Father,
6, The Plaintiff's position on custody Is as follows; Plaintiff Initially at the
conciliation conference expressed his desire to have half of the summer and an
alternating weekend schedule. During the course of the conference, however, two
separate proposals were addressed to the Plaintiff by Defendant. The first proposal
provided Father with three out of four weekends over the course of the year and
four uninterrupted weeks over the course of the year, permitting him to take one
two week consecutive period. The other proposal was to provide him with every
other weekend and a total of five uninterrupted weeks over the course of the year,
with a provision that he could take two of those weeks consecutively. The Plaintiff
would not make a final decision at the conciliation. Apparently another proposal
was made after the conciliation but at the time of the writing of this report, the
only position that the Conciliator is aware of is the Plaintiff's desire to have the
children every other weekend and half of the summer.
6, The Defendant's position on custody is as follows: The Defendant
provided the Plaintiff with two different proposals as described above for a
resolution of this case. The Defendant's position is that she is available to take
care of the children during the day since she is working part-time and intends to
continue working part-time until the children are of school age. She believes that
2
the children should not spend six consecutive weeks with the Plaintiff and place
them in a day care setting when she Is otherwise available to provide that care,
Additionally, she indicated that since the children are not of school age, there is no
reason to create a schedule now that essentially provides Father with a large block
of time over the summer months since that Is not an issue at this time. Her
proposal was to provide the Father with regular access to the children and some
blocks of weeks over the course of the year,
7. Need for separate counsel to represent children; Neither party requested
and the Conciliator does not believe any is necessary.
8. Need for independent psychological evaluation or counseling; Neither
party requested and the Conciliator does not believe any is necessary.
9. A hearing in this matter shall take two hours.
10. Other comments: The parties are the parents of two young children,
ages 4 and 3. When they separated, Mother moved back to her home in
Selinsgrove to be near her family. Mother was at home during the time that the
parties resided together and is working part-time in order to allow her to be home to
take care of the children. Essentially, her work hours are on the weekends. Mother
proposed a schedule which would allow the children to be with their father during
the weekends when she was working and to be with her while Father was working.
She also made a proposal to provide him with between four and five weeks over
3
the course of the year but only two consecutively so that the children will be with
him for extended pariods.
The Father was adamant that he be provided with a large block of time
during the summer. He also requested that the children be with him every other
weekend,
The proposal made by Mother in this case actually provided Father with the
same or more time then he is requesting. However, the Father seemed to place
significance on having the children now for six consecutive weeks during the
summer even though the children are not in school at this point.
The parties both recognize that the Father should have regular and consistent
access and all of the proposals made will reach that end. The court will have to
make a decision as to which is the appropriate schedule If the parties cannot reach
an agreement prior to the hearing.
Date: 4 April 1996
Michael L, Bangs
Custody Conciliator
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MICHAEL, J, RIORDAN,
Plaintiff
vs
JENNIFER J. RIORDAN,
Defendant
004
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 96-818 CIVIL TERM
IN DIVORCE/CUSTODY
RDER
AND NOW, this (Z day of Yom..--
--)-u -_-.---_.-_, 1996, upon the
Stipulation of the parties, as evidenced by their counsel, we hereby order and decree as
follows:
1. The parties shall share legal custody of their minor children, Olivia J. Riordan,
d.o.b, 27 August 1991, and Savanah E. Riordan, d,o.b. 5 December 1993.
2, Primary physical custody of the said minor children is hereby awarded to their
mother, the Defendant Jennifer J. Riordan,
3, The father of the children, the Plaintiff Michael J. Riordan, shall have and
enjoy the following periods of temporary or partial custody with both children:
A. Alternating weekends, from Friday at 5:30 p.m. until Sunday at
5:30 p,m., commencing with the weekend of Friday, March 10, 1996 and
continuing on an alternating basis thereafter.
B. Five weeks each year, none of which shall be consecutive and
none of which will fall over the Christmas, Thanksgiving or Easter
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vacations, Each week shall be seven (7) days in length and, by connecting
them to the Father's periods of alternating weekend custody, the Father
shall actually have the children tier nine (9) days each of those weeks. The
Father must give the Mother at least two weeks advance notice of any of his
weeks of such custody,
C. The parties shall alternate the following major holidays: New
Year's Day, Memorial Day, Fou?lh of July, and Labor Day. Father will
have New Year's Day and Fourth of July in even-numbered years and will
have Memorial Day and Labor Day in odd-numbered years, while Mother
will have New Year's Day and Fourth of July in odd-numbered years and
Memorial Day and Labor Day in even-numbered years. These periods of
partial custody will be from 9:00 a.m. until 7:00 p.m., except that if they
occur on a regular weekend period of custody to be detennined with the
Father, then he may extend the custody weekend to include that day and
return the children at 7:00 p.m. on that holiday.
D. The Easter holiday shall be broken into two segments which
shall be alternated. Segment A shall occur from Saturday at 3:00 p.m. until
Easter Sunday at 2:00 p.m, Segment B shall occur from Easter Sunday at
2:00 p.m. until 8:00 p.m. In 1996 and all even-numbered years thereafter,
Mother shall have Segment A and Father shall have Segment B. In 1997
and all odd-numbered years thereafter, Father will have Segment A and
A
Mother will have Segment B,
E. The'rhanksgiving holiday will be broken into two segments
which shall be alternated. Segment A shall occur from Wednesday at 5:00
p,m, until Thanksgiving Day at 3:00 p,m. Segment 13 shall occur from
Thanksgiving Day at 3:00 p.m, until Friday at 7:00 p.m, In 1996 and all
evert-numbered years thereatier, Father will have Segment A and Mother
will have Segment B. In 1197 and all odd-numbered years thereatier,
Mother will have Segment A and Father will have Segment 13,
F. The Christmas holiday will be broken into two segments which
shall be alternated. Segment A shall occur from 12:00 noon on Christmas
Eve until 12:00 noon on Christmas Day. Segment B shall occur from 12:00
noon on Chrisnmas Day until 12:00 noon on 26 December. In 1996 and all
even-numbered years thereafter, Father shall have Segment A and Mother
shall have Scgment B, while in 1997 and all odd-numbered years thereafter,
Mother shall have Segment A and Father shall have Segment B.
4, The parties shall share transportation by meeting at a midpoint between their
homes for the custody exchanges contennplated by this Order.
/ j
BY'fHECOU,
J.
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1
MICHAEL J, RIORDAN, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND
VB COUNTY, PENNSYLVANIA
)
JENNIFER J. RIORDAN, CIVIL ACTION -LAW
Defendant ) NO. 96-818 CIVIL TERM
IN DIVORCE/CUSTODY
STIPl1LAT10N
AND NOW come the above-named parties, by their attorneys, signed below,
stipulate and agree that the attached Order shall be entered to resolve the current disputes
in the above-captioned matter, said Order to be effective immediately,
l
Barbara Sumple-Sullivan, Esquire
Attorney for Michael J. Riordan
Samu . Andes, Esquire
Attorney for Jennifer L, Riordan
,
b
MICHAEL J, RIORDAN,, t IN THE COURT OF COMMON PLEAS
t CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff t
t NO, 96-818 CIVIL TERM
JENNIFER J. RIORDAN,
t I
Defendant ; CIVIC. ACTION LAW
t IN DIVORCEICUSTODY
I
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RUE
AND NOW, this _h_ day of , 1997, upon the consideration of the
foregoing Motion, a Rule is Issued upon the parties to this action to show cause, if any they
have, why the relief requested in said Motion should not be granted,
RULE RETURNABLE within, days from the date of service hereof.
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MICHAEL J, RIORDANo t IN THE COURT OF COMMON PLEAS,
t CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff t
c NO, 96-818 CIVIL TERM
V.
JENIFER J. RIORDAN,
? I
Defendant CIVIL ACTION LAW
IN DIVORCE/CUSTODY
I
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ORDER
Now this day of 1997, upon consideration of the ' motion of '
BARBARA SUMPLE-SULLIVAN, ESQUIRE, to withdraw from this case, leave Is given said
counsel to withdraw,
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MICHAEL J, RIORDAN,
Plaintiff
V, ,
JENNIFER J. RIORDAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 96.818 CIVIL TERM
CIVIL ACTION LAW
IN DIVORCE/CUSTODY
viOTION 7'Q ?`?ITFIDRA?OUNSEL
And now, to wit, this 27n day of January, 1997, comes Barbara Sumple-Sullivan,
Esquire, and files the within Motion to withdraw for the following reasons;
On or about January 26, 1996, Michael J. Riordan, Plaintiff contracted with the
law firm of Barbara Sumple-Sullivan, Esquire in connection with the above-
referenced divorce/custody, A copy of said agreement is attached hereto as
Exhibit A. ,
Z Pursuant to that representation, the litigation involving this case is continuing,
l 3, That despite numerous requests, Plaintiff has refused cooperate in proceeding
with this case, by not advising Counsel of his telephone number, returning phone
calls or otherwise maintaining contact with Movant's office.
I
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4, The Plaintiff has pursisled h) a course of cmnluel that Mova?)l bulleves In
Imprudent and not In furtherance of the proper olquelives of Ihu Illlgallon,
ii
Ij 5, Due to Plaintiff's acilons, el'fecllve repreNemmulon has been nmdered unreasonably
j
difficult, due to the Plaintiff not ndvlsh)g Movam of the NhtU)s of tits case.
b, Plaintiff has failed to fulfill his obligation ha the Movant regarding the agreement
I
j for services and has bean given reasonable notice that payment for services Is due
I!
and Payable.
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7, Barbara Sumple-Sullivan, ENquire, bus monles ih)e and owing for attorney's fees,
com and expenses as it result of representb?g the Plaintiff, and further
representmim) will reNUlt In an unreasonable financial hurden on the Movant,
i
WHEREFORE, Barbara Sumplu-SullIvan, lisquire, requests don she be withdrawn as
counsel and that Michael J, Riordan be ordered and/or dlrecled to find anolher counsel,
aqY drloge Street
New Cumberland, PA 17070.1931
(717) 774-1445
Supreme Court 1,1), 32317
2
Raspeclfully subnnittcd,
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BARBARA LAW 0l1Pjt;IjN
n•?u nunwrl Nruun
NOW G" "'"Nn, PHNNMYLVANIA 170711.111111
PIIoNI: uul rral.aln
NAB P n la ino
TO MY CLIENTS; POLICY REGARUINU ,
SI?RVICI:, hRIiS & RETAINER
Quality legal service requires skill and time, My skill and 11111e is illy "stock In trade" •• and
generally my fees ere based on skill and cline expended
It is always proper for you, my client, to
discuss fee urruegeneenlsl progress In the matter or
details of a particular bill, It will help you and I if you w,
any questions you may have. nlld rend this explanation and discuss
'1'YI'1{ti (11? 1?1?I?ti
CON I TATIO " For an initial cnnsullnt{un, charges
Pend with you prlnulrlly will be based on the time J
further s before you, c my consultation reveafx 111,11 1 nerd w suuly the law or faces of your case
I decide )o lake It, I will dlsruss 111Lx further slop, and the fee, if any, with you.
STANDARD Fne d deeds and 1 willswill.qunle a fixed fee fur Noll"' slnndiu'diied services such as the
draftingof routine
CONTIN( FNT FE S In some situatinnN hevolvhlg Inwsults for recovery of a sum of
money [personal injury suits, for exangelel I will receive 11 fixed percenlag' of the total recovery
as compensation for handling the case. Ilowever, all ex nnlst paid he you and kept
current on a monthly basis, p'res's he
YARIAB["E OR HO RI Y i I In n"nst rrutlters
$100.00. I shall be pleased, however, to furnLvl, you will, nn I will charge an hourly rate of spend on the matter idea of the approximate time I will
. However, this figure con only he a rough es the a
RETAIN Eft ;. expenses This which 1 office expect luests
for costs and l 11 *
bSgU.t)t] retainer fee. I Ile fee Is generally a deposit
retainer Is non-refundable, incur when" I ngrve 11) proceed with your matter. The
.
CBARQ -. My office will keep aceurate records of the time expended and services
performed on your "natter, When I send you Illy hill, I will specify the time spent on your
matter, how It was spent, and the charge for that Ihnc, actual
disbursements 1 make on your behalf, In nddiliSpe you will time
billed for
days. Balances You will will be billed around tile
days 15th of each month. I expect payment within 30
, Bala b' charged helereq at 111' rare of I% per month,
MOST IMPORTANT, 11' YOU IIAVI,; ANY QUESTIONS, PLEASE ASK THEM11
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P $LI2 Y REGARDING SERVICE, FEES & RETAINER
January 26, 1996
' III I
I understand and agree with the foregoing policy regarding service, L
fees and retainer,
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at'1-
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549 Bridge Street
New Cumberland, PA 17070.1931
I.
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,
MICHAEL J, RIORDAN,
Plaintiff
v,
JENNIFER J. RIORDAN,
Defendant
,
IN TIIE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NU, YO-51CS LIVn leml
,
;
IN DIVORCE/CUSTODY
CERTIFICATE OF SERVICE
I, BARBARA SUMPLE•SULLIVAN, ESQUIRE, do hereby certify that on this date.
I served a true and correct copy of the MOTION TO WPI'IIDRAW AS COUNSEL, in the
above captioned matter upon the following individual(s), by United States first-class mail,
postage prepaid, addressed as follows,
Mr. Michael J. Riordan Jennifer J. Riordan
1103 Dry Powder Circle CIO Samuel Andes, Esquire
Mechanicsburg, PA 17055 525 North Twelfth Street
Lemoyne, PA 17043
i
DA?E;
Barbera Sumplc-Sullivan, Esquire
j, 549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court LD, 32317
L':., t
MICHAEL J. RIORDAN,
Plaintiff
i!
V.
JENNIFER J. RIORDAN,
Defendant
?I
it
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t IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
NO. 96818 CIVIL TERM
:
CIVIL ACTION LAW
IN DIVORCE/CUSTODY
l
1, BARBARA SUMPLE-SULLIVAN, ESQUIRE, hereby certify that the facts set forth
in the foregoing MOTION are 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. I further aver that this Motion Is
not interposed for the purpose of delay.
DATE: (Z 7
B rbara Sumple-SullIvan, Esquire
549 Bridge Street
New Cumberland, PA 17070.1931
(717) 774.1445
j Supreme Court I.D. 32317
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APR U 31991 -
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MICHAEL J. RIORDAN, IN THE COURT OF COMMON PLEAS
I t
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
I
V t NO, 96-818 CIVIL TERM
i. JENNIFER J. RIORDAN,
i
I Defendant CIVIL ACTION LAW
t
t IN DIVORCE/CUSTODY
' I
' ? ORDFB
AND NOW, TO WIT, thisZ day of ADJUDGED and DECREED that: y 1997 it is ORDERED,
1, The Rule to Show Cause is made Absolute:
2, The appearance of Barbara Sumple-Sullivan, Esquire, as counsel for the Plaintiff,
Michael J. Riordan, in the above-stated action, is hereby withdrawn.,
Ir i J
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MICHAEL J. RIORDAN, t IN THE COURT OF COMMON PLEAS
t CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff t
t NO, 96.818 CIVIL TERM
V.
JENNIFER J. RIORDAN,
,
Defendant ; CIVIL ACTION LAW
t IN DIVORCE/CUSTODY
I
MOTION TO MAKE RULE ABSOLUTE
And now, to, wit, this/ day of March, 1997, comes Barbara Sumple•Sullivan, Esquire,
is
and files the within Motion to withdraw for the following reasons:
I
1, Petitioner Is Barbera Sumple-Sullivan, Esquire.
2, Respondents are Michael J. Riordan and Samuel Andes, Esquire,
3, On February 3, 1997, Petitioner filed a Motion to Withdraw as Counsel for
IMichael J. Riordan.
4,, On March 11, 1997, The Honorable Edgar B. Bayley issued a Rule, returnable
I
i
within ten (10) days, to show cause why Petitioner should not be allowed to
withdraw as counsel in this ease. A copy of said rule is attached hereto as
, Exhibit A and incorporated here unto is incorporated by reference herein.
?I
5, No objection has been flied to (laic. Copies of said rule were served on
Respondents by regular mail. Copies of said correspondence is attached as
Exhibit B and incorporated by reference herein.
6. Having received no objection to date, Petitioner hereby requests leave to with
draw as counsel for Plaintiff, Michael J, Riordan,
WHEREFORE, Barbara Sumple-Sullivan, Esquire, requests that she be withdrawn as
counsel of record,
'Respectfully ;u mitred,
,.
DATE:
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court LD. 32317
I
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MICHAEL J. RIORDAN,
. IN THE COURT OF COMMON PLEAS
t'CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff t
V NO, 96.818 CIVIL TERM
JENNIFER J. RIORDAN,
Defendant' t
t CIVIL ACTION LAW
t IN DIVORCE/CUSTOgy
!iLl1,E
AND NOW, this day of att?i. 1997, upon the consideration of the
- Z22 foregoing Motion, a Rule is issued upon the parties to this action to show cause, if any they
have, why the relief requested in said Motion should not be granted.
RULE RETURNABLE within, IC days from the date of service hereof,
,
J
In TTRI,PE1 C"'PY FROM RECORD
untoset my or4d hand
Iite stet of said Court at Carlisle, Pe,
This ., JR,, day of.,,,'M,ati 19,1?.z
,Protltorto?ry
.-A
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EXHIBIT "B"
y
,
LAW orricas
BARBARA SU"LE•SULLIVAN
549 BRIDGE STREET
NEW GVNEERLAND, PENNSYLVANIA 17070.1901
PRONE (717) 774/14415
FA)t (7I7) 774/70159
,
March 12, 1997
I
I
Mr, Michael Riordan Samuel Andes, Esquire
1103 Dry Powder Circle 525 N, Twelfth Street
Mechanicsburg, PA 17055, Lemoyne, PA 17043
IDear Mr. Riordan and Mr, Andes:
Enclosed, constituting service on you, is a Rule to Show Cause why my appearance on
behalf of Mr, Riordan should not be terminated,
Said rule is returnable within ten days from the date of set ce hereof.,
Very t y yo
/ I
[ Barbara Sumple-Sullivan ??`
BSS/se
Enclosure
I
I I:
I , I
(i
MICHAEL J. RIORDAN,
Plaintiff
V,
JENNIFER J, RIORDAN,
Defendant
i
i IN THE COURT OF COMMON PLEAS
t CUMBERLAND COUNTY, PENNSYLVANIA
t
NO. 96.818 CIVIL TERM
t CIVIL ACTION LAW
t IN DIVORCE/CUSTODY
f
iI I
VERIFICATION
i 1; BARBARA SUMPLE-SULLIVAN, ESQUIRE, hereby certify that the facts set forth
i
in the foregoing MOTION are true and correct to the best of my knowledge, information and
belief, I understand that any false statements mode herein are subject to penalties of 18 Pa.
C,S,A. $4904 relating to unsworn falsification to authorities. I further over that this Motion is
not interposed for the purpose of delay,
DATE:
arbara p e-Sulliva Y
549 Bridge Street
New Cumberland, PA 17070.1931
(717) 774-1445
Supreme Court I.D. 32317
i
I
MICHAEL J. RIORDAN, t IN THE COURT OF COMMON PLEAS
Plaintiff t CUMBERLAND COUNTY, PENNSYLVANIA
i t
V. t NO, 96.818 Civil Tern
JENNIFER J. RIORDAN, t
Defendant t IN DIVORCE/CUSTODY
i
if
CERTIFICATE OF SERVICE
If, BARBARA SVMPLE•SULLIVAN, ESQUIRE, do hereby certify that on this date,
I served a true and correct copy of the MOTION TO MAKE RULE ABSOLUTE, in the above-
captioned matter upon the following individual(s), by United States first-class mail, postage
i
prepaid, addressed as follows;
Mr. Michael J. Riordan Jennifer J. Riordan
1103 Dry Powder Circle C/O Samuel Andes, Esquire
Mechanicsburg, PA 17055 525 North Twelfth Street
Lemoyne, PA 17043
,I
7
?i
DATE:
Barbera Sumple-Sullivan, Esquire "
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. 32317
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MICHAEL J. RIORDAN,
Plaintiff
VS.
JENNIFER J. RIORDAN,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1996-818 CIVIL TERM
IN DIVORCE
NOTICE TO PLAINTIFF
If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit
within twenty (20) days after this affidavit has been served on you or the statements will be admitted.
DEFENDANT'S AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. The parties to this action separated in January of 1995 and have continued to live separately and
apart for a period of at least two years.
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 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.
f .1
Date: d
JE IFER J RIORDAN
MICHAEL J. RIORDAN,
Plaintiff
VS.
JENNIFER J. RIORDAN,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1996-818 CIVIL TERM
IN DIVORCE
PLAINTIFF'S COUNTER-AFFIDAVIT
UNDER SECTION 3301LD1 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 because
(check (i), (ii) or both):
(i) The parties to this action have not
lived separate and apart for a period
of at least 2 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 this Counter-Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date:
MICHAEL J. RIORDAN
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.
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MICHAEL J. RIORDAN,
Plaintiff
vs.
JENNIFER J. RIORDAN,
Defendant
'IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1996-818 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE BY CERTIFIED MAIL
AMY HARKINS, being duly sworn according to law, deposes and says as follows:
1. That she is an employee of Samuel L. Andes, attorney for the Plaintiff herein.
2. That on 6 March 2008 she delivered to the U.S. Postal Service in Lemoyne,
Pennsylvania, as certified mail (Receipt No. 7007 3020 0001 1088 3316), return receipt
requested, addressed to the Plaintiff herein, a true and correct copy of Defendant's Affidavit
Under Section 3301(d) of the Divorce Code together with a Counter-Affidavit Under Section
3301(d) of the Divorce Code duly endorsed with a Notice to Plaintiff.
3. Said return receipt card is attached hereto as Exhibit A showing a date of delivery
to the Plaintiff of 7 March 2008.
Amy a ins
Sworn to and subscribed
before me this 134~ day
of /V\,.a,, , 2008.
Notary Public MWAlMM.
LVM Drava D, NCTMY P=X
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..._w.....?.........._.,_.,., ..?.?.._,r_...,„,..., ,
;?;?,iA ti'j?ti{.!L}?i f1;":i'+c4"J'ss.1-? r!?''.t_
y,., w.. ? . , .... ...
¦ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
/\A1&'ae1 J, R?orcQq,?
?oc) CC'CQGtf` 'V`i e ?vre
A. Signature
'`] ° ? Agent
XL/ ? Addressee
t3: Received by ( ntetd Name) C. Die of Oeliverv
D. Is delivery address different from item 1? f ? l?s
If YES, enter delivery address below: ? No
9 UA? Nom..
3. Service Type - \ lewd
Certified Mail ? Expre Mc-/
? Registered ? Return Re 1•o a
? Insured Mail ? C.O.D.
4. Restricted Delivery? (Extra Fee) ? Yes
2. Article Numbe
(Transfer from 7007 3020 0001 1088 3316
PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1540
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2-1
MICHAEL J. RIORDAN,
Plaintiff
VS.
JENNIFER J. RIORDAN,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1996-818 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned certifies that, on 13 May 2008, she served a Notice of Intention to Request Entry of
Divorce Decree, a Plaintiff's counter-affidavit, and a copy of the Praecipe to Transmit Record, with a cover
letter dated 13 May 2008, copies of which are attached hereto and marked as Exhibit A, upon the Plaintiff
by depositing the same in the U.S. Mail, postage prepaid, first-class mail, addressed as follows:
Michael J. Riordan
601 Cedar Ridge Lane
Mechanicsburg, PA 17055
Said mailing was not returned to the undersigned by the U.S. Postal Service.
Amy H ns
Sworn to and subscribed
before me this 4 day
of :1 U,N e , 2008.
Notary Public.
OWN"
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12M VW?011f???misft
MrCAMMfMON?M?ls 1
A AM
FILE COPY
SAMUEL L. ANDES
ATTORNEY AT LAW
525 NORTH TWELFTH STREET
LEMOYNE, PENNSYLVANIA 17043
Mailing Address:
P.O. Box 168
Lemoyne, PA 17043-0168
13 May 2008
Telephone: (717) 761-5361
Fax: (717) 761-1435
E-Mail: LawAndes Q aol.com
Mr. Michael J. Riordan
601 Cedar Ridge Lane
Mechanicsburg, PA 17055
Dear Mr. Riordan:
I am now in a position to conclude the divorce action which you filed against
Jennifer in 1996. Enclosed is a second set of notices to you. I will file the praecipe to
transmit the record, which will present to the court the documents necessary to conclude
the divorce, in the near future. Please contact an attorney if you have any questions.
Sincerely,
le
Enclosure
Samuel L. Andes
cc: Ms. Jennifer Riordan
MICHAEL J. RIORDAN,
Plaintiff
vs.
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 96-818 CIVIL TERM
IN DIVORCE
JENNIFER J. RIORDAN,
Defendant
NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE
TO: Michael J. Riordan
601 Cedar Ridge Lane
Mechanicsburg, PA 17055
You have been sued in an action for divorce. You have failed to answer the
Complaint or file a Counter-Affidavit to the Plaintiff's Affidavit. Therefore, on or after
Lk 7u4e
2008, 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 Answer with your signature
notarized or verified or a Counter-Affidavit 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 COUNTER-AFFIDAVIT WHICH YOU MAY
FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY 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 Court House
1. Courthouse Square
Carlisle, PA 17013
Telephone: (717) 240-6200
MICHAEL J. RIORDAN,
Plaintiff
vs.
JENNIFER J. RIORDAN,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 96-818 CIVIL TERM
IN DIVORCE
PLAINTIFF'S COUNTER-AFFIDAVIT
UNDER SECTION 3301(D) 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 because
(check (i), (ii) or both):
(i) The parties to this action have not lived separate and apart
for a period of at least 2 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 this Counter-Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
Date:
MICHAEL J. RIORDAN
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.
MICHAEL J. RIORDAN,
Plaintiff
VS.
JENNIFER J. RIORDAN,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 96-818 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT 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 Section 3301(d).
2. Date and manner of service of the Complaint:
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 Plaintiff: N/A by Defendant: N/A
(b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code:
22 February 2008 (2) Date of filing and service of the Defendant's Affidavit upon the Respondent:
filed 4 March 2008, served by certified mail on 7 March 2008.
4. Related claims pending: None
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit
Record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: Date Defendant's Waiver of Notice in Section 3301(c) Divorce was
filed with the Prothonotary:
Date:
By
Samuel L. Andes
Attorney for Defendant
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MICHAEL J. RIORDAN,
Plaintiff
vs.
JENNIFER J. RIORDAN,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 96-818 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT 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 Section 3301(d).
2. Date and manner of service of the Complaint:
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 Plaintiff: N/A by Defendant: N/A
(b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code:
22 February 2008 (2) Date of filing and service of the Defendant's Affidavit upon the Respondent:
filed 4 March 2008, served by certified mail on 7 March 2008.
4. Related claims pending: None
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit
Record, a copy of which is attached: 13 May 2008 by U.S. Mail.
(b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: Date Defendant's Waiver of Notice in Section 3301(c) Divorce was
filed with the Prothonotary:
Date: /3 ?t1Q_ ('' B
Sa . Andes
Attorney for Defendant
om o
t
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-r _...y
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
MICHAEL J. RIORDAN,
Plaintiff
VERSUS
JENNIFER J. RIORDAN,
Defendant
No. 96-818 CIVIL TERM
DECREE IN
DIVORCE
AND NOW, Auv'Q %I , _2QQ$, IT IS ORDERED AND
DECREED THAT MICHAEL J. RIORDAN
AND
JENNIFER J. RIORDAN
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
,DEFENDANT,
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;
3a, Ll -
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