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Home My WebLink About96-01459 " \ ~ \ \..... "'...; ....,. J J / j ! -..3 i .-- i ! i ,(),~ "0 DEBRA D. HOWE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 96-1459 CIVIL TERM CIVIL ACTION - AT LAW DIVORCE vs. CHARLES L. HOWE, Defendant ORDER OF COURT AND NOW, this _1'\<",1, ;r) I(Hr., upon consideration of the , attached complaint, it is hereby directed that the parties and their respective counsel appear before IVl,. ~'''' I t. 1';(",>... t "', , the conciliator, at 7){,,)., I;; II, "J I (''''If 1/;" , on ;;;p the ~ day of ~'/ . , 1996 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: I') By: t'lVf,...o-lr'i r;,U(U"$/ Custody Conciliator v _/_., ,; --y:# YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT Al'FORD 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 '-' DEBRA D. HOWE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ;/,1) I} 1 ')t \ v. NO. i (, 'I. IL, C. 11-- CHARLES L. HOWE, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must taks prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse in Carlisle, Pennsylvania , IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. I I COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE i 1 COURTHOUSE SQUARE \ CARLISLE, PA 17013 (717) 697-0531 I 7. The Plaintiff has been advised that counseling is I available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree of Divorce in this matter. COUNT II - CUSTODY 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. The parties are the parents of the following unemancipated children who resides with the Plaintiff, Debra D. Howe and Defendant, Charles L. Howe: NAME AGE DATE OF BIRTH Jessica M. Howe Andrew R. Howe Marie L. Howe Shawn E. Howe 11 years 9 rears 6 years 5 years 6-15-84 8-15-86 10-12-89 10-20-90 11. Plaintiff has not participated in any other litigation concerning the children in this or any other state. 12. There are no other proceedings pending involving custody of the children in this or any other state. 13. Plaintiff knows of no person not a party to these proceedings who has physical custody of the children or who claims to have custody, partial custody or visitation rights with respect I to the children. DEBRA D. HOWE, IN ~HE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . v. NO. . . CHARLES L. HOWE, CIVIL ACTION - LAW Defendant IN DIVORCE VERIFICATION I, Debra D. Howe, state that I am the Plaintiff in the above-captioned case and that the facts set forth in the above Complaint are true e.nd correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. S 4940. ,,/, ~),lb- cJ ~ll- DEBRA D. HOWE ~ I ' Date: '3 'I/(/71rf. / / ,..-..or' \. " 1 \'0 !,. . . r-,~ ~ ~.I': 1.._____ --, r-..:::r '- ~ .L . "-...-1 .........., \~~ - -' ....... ~ - \ .",,-) ---' ........ .~ ."'..... \ ........ ~"l \ ~...) ~.- . .~ ',) " "! \.- /" , '-. VCi '\.I. '......, ;,:) ...~ I """, . ~ -,.J ~ .... ~~ J i~ ~ :s.. Jj '3 Li ~F:1~~~ ~s ~ < tE ;<~' u ~ Q.; PATRICK F. LAIlER, JR. Atlorncy at Law lltJl( Markel SIn:cl I\IIC~ HUlhlin~ C.UI1[lIlIIl.l'A 17011 (717) 1tlJ IKOO , t " - Ii I , I I DEBRA D. HOWE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-1459 CIVIL TERM . . CHARLES L. HOWE, . CIVIL ACTION - LAW . Defendant . IN DIVORCE . PETITION FOR RIGHT TO RESIDE IN MARITAL RESIDENCB PURSUANT TO 23 Pa. C.S.A. S 3502/cl AND NOW, comes the Plaintiff, Debra D. Howe, by and through her attorneys, The Law Offices of Patrick F. Lauer, Jr., respectfully avers the following in support of her Ptitition for Special Relief I 1. Petitioner in this matter is Plaintiff, Debra D. Howe. 2. Respondent in this matter is Defendant, Charles L. Howe. 3. A Complaint in Divorce was filed with the Cumberland County Prothonotary's Office on March 15, 1996. 4. As of the date of the filing of this Petition, the Court has not yet ruled upon the divorce of the parties. 5. Pursuant to 23 Pa. R.C.P. S 3502(c:, Plaintiff requests that she be granted exclusive possession of the marital residence for the following reasons: a. The parties are the adoptive parents of Jessica 1M. Howe, Andrew R. Howe, Marie L. Howe, and Shawn E. Howe, ranging in ages 5 years old to 11 years old; DEBRA D. HOWE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : v. NO. 96-1459 CIVIL TERM . . CHARLES L. HOWE, . CIVIL ACTION - LAW . Defendant IN DIVORCE VERIFICATION I, Debra D. Howe, state that I am the Petitioner in the above-captioned case and that the facts set forth in the above Petition are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. S 4540. () 6/ It It.J (", ;(/ , }\L4j 1.li,1 -) .I" ) / i/,' Date: 1/,/L_/n I / . . DEBRA D. HOWE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. CIVIL ACTION - LAW IN DIVORCE CHARLES L. HOWE, : Defendant : 96-1459 CIVIL TERM IN RE: CUSTODY ORDER OF COURT AND NOW, this 12th day of August, 1996, upon consideration of the custody complaint filed in the above-captioned matter, and pursuant to an agreement reached between the parties in open court (the plaintiff, Debra D. Howe, being represented by Matthew Eshelman, Esquire, and the Defendant representing himself), it is ORDERED and DIRECTED with respect to custody of the parties' four children, Marie Lynn Howe (date of birth: October 12, 1989), Shawn Edward Howe (date of birth: October 20, 1990), Andrew Richard Howe (date of birth: August 15, 1986), and Jessica Marie Howe (date of birth: June 15, 1984) as follows: 1. Legal custody shall be shared by the parties. 2. Primary physical custody shall be in the mother with liberal periods of temporary or partial custody to be afforded to the father upon reasonable notice to the mother. Both parties have agreed that the natural mother of these adopted children should not be permitted to see or visit with the children. " ,i} >- ..... ;,... cI; ~;~ ~'~-: C. e ' " -t" . 1-'-' ~- .~ ).,~ li~ ~) ~ lI-rl '.-, :~ ~_. ff) , . ,,::, " ,;!~ lJ.'L- , , _+J[ $. u: "' .. 'J5: l-~- -. lL .....:1 "":3 (.) f:. W DEBRA D. HOWE, IN THE COURT OF COMMON PLEAS OF Plaintif f : CUMBERLAND COUNTY PENNSYLVANIA I ve. I No. 96 - 1459 Civil Term I CHARL.!S L. HOWE, I CIVIL ACTION - LAW Defendant : IN DIVORCE PLAUI'l'IFl'" S AFFIDAVIT OF COHSB!I'l' mil2iR SECTION :nUL.2,LJ2l.. TJ.ULPJVORCB COOS 1. A complaint in divorce under Section 3301(c) of the ,; Divorce Code was filed on March 15, 1996. , 2. The marriage of the Plaintiff and the Defendant ie i irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. S 4904 relating to :1 unsworn falsification to ;1 :i ': j: DATE: 'i 'I :1 ,~:y /77 / authorities. Q/ (1;/1 Signature: ' ..F",. liJ .f.t(~d{ Debra D. Howe il Ii ij . Ii