HomeMy WebLinkAbout96-02556
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: IN THE COURT OF COMMON PLEAS :
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OF CUMBERLAND COUNTY
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STATE OF rt~.\ t PENNA.
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JUDITH E. MATHES
i'\1l.!l6-2556 ...CIVU II)
Vt'I';.;II:;
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DANIEL R. MATHES
DECREE IN
DIVORCE
AND NOW,..... ..~~.y..... ..~.~~'........ 19. ~?.... It Is ordered and
decreed that.... Ju.q!Hl..~ ,. ~.1\11.1~.S.......................... plaintiff,
and... .ollN.1.n. R... .f:I/I.Tms................................... defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record In this octlon for which a final order has not yet
been entered;
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between each other, in accordance with the provisio~s of the
Divorce Code.
NOW THEREFORE, considering the above conditions and
circumstances, and in consideration of the covenants and
promises hereinafter to be mutually kept and performed by
each party, as well as for other good and valuable
consideration, and intending to be legally bound hereby, it
is agreed as follows:
1.
It shall be lawful for each party at all times
hereafter to live separate and apart from the other party at
such place or places as he or she from time to time may
choose or deem fit.
2.
Each party shall be free from interference, authority
and control, direct or indirect, by the other as fully as if
he or she were single and unmarried. Neither shall molest
the other or compel or endeavor to compel the other to
cohabitate or dwell with him or her.
3.
The parties have divided between them to their mutual
satisfaction the personal effects, household furniture and
furnishings, and all other articles of personal property
which have heretofore been used by them in cornmon. Husband
to receive stereo system.
4 .
The parties hereto nr~ owners as tenant~ by the
entirety of real estate situate at 305 Walnut Street,
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Boiling Springs, Cumberland County, Pennsylvania, 17007.
Husband agrees to convey the property to Wife. On and after
the date of transfer of said property from Husband to Wife,
Wife shall assume and be responsible for all obligations on
the property, all real estate taxes, mortgage, repairs,
utilities, maintenance and insurance.
Wife agrees to
indemnify and save and hold harmless Husband from any and
all liability and/or claims and/or damages and/or expense
Wife may sustain or for which she may become liable in any
way.
5.
Husband to pay on loan H107855-6 at Members First at
$135. a month with a balance of $2,400. Husband shall pay
the balance due on the Members
First Visa Acct.
H4287590002062590 with a balance of about $3,100. and make
every effort to refinance these loans in his name alone.
Wife agrees to pay the Bon Ton bill.
She will also make
loan payments of $179. a month on loan H107855-5 with an
approximate balance of $3,500.
6.
Husband
maintain
to
the
children
agrees
as
beneficiaries on any life insurance on his life until the
youngest child attains the age of 21 in the amount of
$100,000.
7.
Wife relinquishes her inchoate intestate right in the
estate of Hll.~band. and IlUSbdllU relinquishes his inchoate
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intestate right in the estate of Wife, and each of the
parties hereto, by these presents for himself or herself,
his or her heirs, executors, administrators or assigns, does
remise, release, quit-claim and forever discharge the other
party hereto, his or her heirs, executors, administrators or
assigns, or any of them, of any and all claims, demands,
damages, actions, cause of action, or suite at law or in
equity of whatsoever kind of nature, for or because of a
matter or thing done, omitted or suffered to be done by said
party prior to and including the date hereof, except that
this release shall in no way affect any cause of action in
any absolute divorce which either party may have against the
other of whatever nature, arising or which may arise, under
this Agreement or for the breach of any provision thereof.
8.
Nothing contained in this Agreement shall be deemed to
prevent either of the parties from maintaining a suit for
absolute divorce against each other in any jurisdiction
based upon any of the grounds for divorce specified in 23
Pa. C.S.A. H3301 of the Pennsylvania Divorce Code. In the
event any such action is pursued or initiated, the parties
shall be bound by all the terms of this Agreement.
9,
The parties have attempted to distribute their marital
property in a manner which conforms to the criteria set
forth in 23 Pa. C.S.A. 3502 Pn, C.S.~. 3502 of the
Pennsylvania Divorce Code, and have taken into account all
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considerations set forth therein. The division is being
effected without the introduction of outside funds or
property not constituting marital property. The division of
property under this Agreement shall be in full satisfaction
of all marital rights and any other rights of the parties.
10.
Both parties relinquish and waive all right, title,
claim or interest either may have in the employee benefits
of the other, including but not limited to stock options,
retirement plans and IRA's.
11.
Each of parties shall hereafter own and enjoy,
independently of any claims or rights of the other, all real
property and all items of personal property, tangible or
intangible, acquired after the date of separation of the
parties or hereafter acquired by him or her, with full power
in him or her to dispose of the same as fully and
effectively, in all respects and for all purposes, as though
he or she were unmarried.
12.
Except as specifically provided for herein, both
parties specifically waive any and all rights they may have
at present or hereafter may have for spousal support and
further waive any and all rights they may have at present or
hereafter may have, for alimony, alimony pendente lite, or
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separate maintenance and support as provided in Section 501
of the Divorce Code.
13.
Each party shall be individually responsible for the
payment of his or her own respective attorney's fees and
costs, both for the negotiation and preparation of this
Agreement and also for any divorce action which may be
filed.
14.
Except for any debt or obligation of either party to
the other under this Agreement, each party hereby agrees to
save and hold the other harmless from all personal debts and
obligations incurred by him or her from the date hereof.
15.
Each party represents and warrants to the other that he
or she has not incurred any debt, obligation or other
liabil i ty other than described in this Agreement on which
the other party is or may be liable. Each party covenants
and agrees that if any claim, action or proceeding is
hereinafter 'instituted seeking to hold the other party
liable for any other debts, obligations, liability, act or
omission of such party, such party will, at his or her sole
expense, defend the other against any such claim or demand,
whether or not well-founded, and that he or she will
indemnify and hold harmless the other party in respect to
all damages resulting therefrom. Each party hereby releases
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the other from all claims, liabilities, debts, obligations,
actions and causes of action of every kind that have been or
will be incurred relating to or arising from the marriage
between the parties. However, neither party is relieved or
discharged from any obligations under this Agreement, or
under any instrument or document executed pursuant to this
Agreement.
16.
Neither party shall contract any debt or liability for
which the other party or his or her property or estate might
be responsible, and shall indemnify and save the other
harmless from any and all claims and demands made against
him or her by reason of the debts or obligations incurred by
the other party.
17.
If either party breaches any provision of this
Agreement, the other party shall have the right, at his or
her election, to sue for damages for such breach or seek
such other remedies or relief as may be available to him or
her, and the party breaching this contract shall be
responsible 'for payment of reasonable fees and costs
incurred by the other in enforcing his or her rights under
this Agreement.
18.
Each party acknowledges that he or she has received
independent legal advice from counsel of his or her
selection, and each fully understands the facts and has been
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fully informed as to his or her legal rights and
obligations, and each party acknowledges and accepts that
this Agreement is, under the circumstances, fair and
equitable, and that it is being entered into freely and
voluntarily having received such advice and with such
knowledge, and that the execution of this Agreement is not
the result of any duress or undue influence, and that it is
not the result of any collusion or improper or illegal
agreements.
19.
Each of the parties shall, from time to time, at the
request of the other, execute, acknowledge and deliver to
the other party any And all further instruments which may be
reasonably required to give full force and effect to the
provisions of this Agreement.
20.
This Agreement contains the entire understanding of the
parties and there are no representations, warranties,
covenants or undertakings other than those expressly set
forth herein. Husband and Wife acknowledge and agree that
the provisions of this Agreement with respect to the
distribution and division of marital and separate property
are fair, equitable and satisfactory to them based on the
length of their marriage and other relevant factors which
have been taf:en into consideration by the parties. Both
parties hereby accept the provisions of this Agreement with
respect to the division of property in lieu of and in full
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and final settlement and satisfaction of all claims and
demands that they may now have or hereafter may have against
the other for equitable distribution of their property by
any court of competent jurisdiction pursuant to Section
3301.al of the Divorce Code or any other laws. Husband and
Wife each voluntarily and intelligently waive and relinquish
any right to seek a court-ordered determination and
distribution of marital property, but nothing herein
contained shall constitute a waiver by either party of any
rights to seek relief of any court for the purpose of
enforcing the provisions of this Agreement.
21.
It is understood and agreed by the parties hereto that
Wife has filed an action in divorce in the Court of Cornman
Pleas of Cumberland County in which she has alleged or will
allege that the marriage is irretrievably broken under
Section 3301(cl of the Divorce Code, Both parties further
understand and agree that said divorce on said grounds shall
be pursued and that both parties will file the necessary
Affidavits of Consent and all other petitions and documents
necessary to effectuate the divorce.
22.
A modification or waiver of any of the provisions of
this Agreement shall be effective only if made in writing
and executed with th", same formality as thi:J AgreeHltlllt. The
failur.e of either party to insist upon the strict
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JUDITH E. MATHES . , IN TilE COURT OF COMMON PLEAS OF
. .
. . CUMBERLAND COUNTY, PENNSYLVANIA
. .
v. . . NO. 96-2556 CIVIL
. ,
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DANIEL R. MATHES . , IN DIVORCJ;
. .
PRAECIPE TO TRANSMIT RECORD
To The Prothonotary:
Tr.ansmit the record, together with the following
information, to the court for entry of a divorce decree:
1. Ground for divorce:
Section (3301 (c)) (3301 (d) (1)
out inapplicable section.)
irretrievable breakdown under
of the Divorce Code. (Strike
2. Date and manner of service of the complaint:
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(Complete either paragraph
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3.
(a) or (b).)
(a) Date
required by Section
plaintiff
Mav 21. 1997
of execution of the affidavit of consent
3301(c) of the Divorce Code: by
; by defendant
May 14, 1997
(b) (1) Date of execution of the plaintiff's
affidavit required by Section 3301(d) of the Divorce Code:
; (2) Date of service of the
plaintiff's affidavit upon the defendant:
4. Related claims pending:
None
5. Date and manner of service of the notice of
intention to file praecipe to transmit record, a copy of
which is attached, if the decree is to be entered under
Section 3301(d) of the Divorce Code:
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France~ II:' Del Duca,
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JUDITH E. MATHES . . IN TilE COURT OF COMMON PLEAS OF
. .
. . CUMAERLAND COUNTY, PENNSYLVANIA
. .
v. . . NO. 96- .) 5 'lit, C _l'\L('t j(-1-~
. .
. .
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DANIEL R. MATIlES . . IN DIVORCE
. .
NOTICE TO DEFEND AND CU\IM RIGHTS
YOU HAVE BEEN 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 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 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 COURTIIOUSE, CARLISLE, PENNSYLVANIA, 17013
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
TELEPIlONE THE OFFICE SET FORTH BELOW TO FIND OUT WIlERE YOU
CAN GET LEGAL HELP.
COURT ADMINISTRATOR
Cumberland county Courthouse
Fourth Floor
Carlisle, Pennsylvania, 17013
Telephone: 717-240-6200
'.
. /
Franc~s H. D~l Duca
10 West Iligh st.
Carlisle, PA 17013
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JUDITH E. MATHES . . IN TilE COURT OF COMMON PLEAS OF
. .
. . CUMBERLAND COUNTY, PENNSYLVANIA
. .
v. . . NO. 96-2556 CIVIL
. .
. .
. .
DANIEL R. MATHES . . IN DIVORCE
, .
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the
Divorce Code was filed May 9, 1996.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety days have elapsed from the date of filing the
complaint.
3. I consent to the entry of a final decree of divorce.
4. I have been advised of the availability of marriage
counseling, that I may request that the Court require that my
spouse and I participate in counseling, and that the Court
maintains a list Of marriage counselors in the Prothonotary's
Office, which list is available to me upon request. Being so
advised, I decline to request that the Court require that my
spouse and I participate in counseling.
5. 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 19 Pa.C.S. Sec. 4904 relating to
unsworn falsification to authorities.
Dated:
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JUDITH E. MATHES
: : IN THE COURT OF COMMON PLEAS OF
:: CUMBERLAND COUNTY, PENNSYLVANIA
:: NO. 96-2556 CIVIL
v.
, ,
. .
DANIEL R. MATHES
IN DIVORCE
. .
. .
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301( c ) OF THE DIVORCE CODE
1. I consent to the entry of a final decree without
notice.
2. 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.
3. I understand that I will not be divorced until a
divorce decree is entered by the Court and that a copy of
the decree will be sent to me immediately after it is filed
with the Prothonotary.
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. Sec. 4904
relating to unsworn falsification to authorities.
Dated: 0ll'/1
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AF~'IJ)AVIT 01; NOTICE 01; COl!Nll!!.!!ING
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Daniel H. Mathe!;
. Defenddnt. being duly
sworn ~ccording to law, depones and nays:
1. I hdve been ddvised cf the dVditdbility of
marriage counsel ins and understand that 1 may
request thdt the court require thdt my apouse and
I participate in counsel lng,
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I understand that the court mdintaino d list of
marriage ccunselors in the Dcmestic "elaticns
Office. which list ie available to me upon
reques t ,
3.
Ueinll DO advIoed, I do not r'eql.l'll't lhdt IIw court
require that my spcuse and I p~rtlcipdt" In
counoeling prior to a divorce decree being handed
down by the Court,
I understand thdt fdloe otatcmentn IIcr'ein I1re made
subject to the penalties of IU Pol, C.G. II {.'JO/, l'el.:ltin13 to
unsworn falsification to iluthoritil!o,
PatOI
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HENRY F, COYNE
AnORNEV AT LAW
31101 MARKET STREET
CAMPHILl.,PA '7011
171717:17-0484
-.
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Juomt E. MfI'n1ES . I IN '111E Caul?!' OF ca-M:X'l PLEAS OF
Plaintiff I CUMl3ERlJ\ND COUNI'Y, PENNSYINANIA
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V6. I NO. 9(;-2556 CIVIl.
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DANIEl, R. MfI'n1ES , I CIVIl, AC'l'lON - LAW
Ix.fendanl I IN llIVOllCE
At101M \'IT.m:..ooNSI<:NT
I, A Complaint in Divorce under Section JJO 1 (c) of the Divorce Code was filed on
Mav9.1996 ,19
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninely (90)
days have elapsed from the date of filing the Complaint,
3. 1 consent to the enlry of a final decree of divorce after service of notice of intention
to rcqUC3t entry of the Dccrcc,
1 verify thai the stalements made in this affidavit arc true and correct. 1 understand that
false statements herein arc made SUbjL'Ct to Ihe penallies of 18 Pa. C.S, fi4904, relating to unsworn
falsification 10 authorities.
Dated:
/'1,(/11' '1.1
MfI'n1ES
, .'
HENRY F. COYNE
ATTORNI:V AT LAW
390 I MARKET STREET
CA.....HILL..PA 1701 I
17171737.048.
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JUDI'11l E. MATHES . I IN TIlE COllR'r OF caM)N PLEAS
Plaintiff I OF CUMBERLAND COUNTY. PENNSYLVANIA
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V6. I NO. 96-2556: CIVIL
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DANIEL R. MA'IHES . I CIVIL ACTION - LAW
~fendant I IN DIVORCE
WAIVER OF NOTICE OF INn:NTION TO R":OUfflI' F.NTRY OF ^ mVORCH
IlJoX]lIili UNJmL!lJ.JnlU;LQI~..DIE IlIVORCE CODE
I. I consent 10 !he entry of a Final Decree of Divorce withoul nOlicc,
2. I understand Ihat I may lose righls concerning alimony. division of property.
lawyer's fees or expenses if I do nol claim lhem before a Divorce is granled. I undcrsland !hall
will not be divorced uotil a Divorce Decree is enlered by !he Court and !hat a copy of the Decree
will be senllo me immediately afler il is filed wi!h the Prothonotary,
I verify thallhe slatemenls made in this affidavil are true and correcl. I understand that
falso statements herein arc made subjecl to the penalties of 18 Pa, C,S, 64904. relating 10 unsworn
falsification 10 authorities,
Dated: /'14nyt//
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~endalll
DANIEL R. MA'llIES
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JUDITH E. MATHES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
.
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V
:CIVIL ACTION - LAW
.
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DANIEL R. MATHES,
Defendant
:NO: 96 - 2556 CIVIL TERM
:IN CUSTODY
COURT ORDER
AND NOr'l, this /f.' day of /11O..,f) , 1997, upon
consideration of the attached Custody Cbnciliation Report, it is
ordered and directed as follows:
1. This Court's prior Order of January 7, 1997 is vacated.
2. The Mother, Judi th E. Ma thes, and the Fa ther, Daniel R.
Mathes, shall enjoy shared legal custody of Erin Leigh Mathes,
born October 6, 1983 and Scott Daniel Mathes, born April 24,
1991.
3. The Mother shall enjoy primary physical custody of both
children.
4. The Father shall enjoy temporary physical custody as follows:
A. On one weekend a month at a time to be arranged between
the parties, taking into consideration the parties' work
schedule and the Father's military reserve schedule.
B. At such other times as agreed upon by the parties.
5. The Christmas holiday shall be divided into two parts. The
parties shall each year select a day that is in the middle of
the children's school holidays, which day shall be the date of
exchange of custody. The first part of the holiday shall be
Part A with the second part of the Christmas holiday being
Part B. The parties shall alternate the Christmas holiday by
exercising custody on Part A and Part B of the holiday on an
alternating basis, with the Fat]~er to have the second part
(Part B) of the 1997 Christmas holiday.
6. The parties shall also al ternate custody over the Thanksgiving
holiday with the Father having Thanksgiving 1997, and the
parties shall alternate custody over the Spring break/Easter
holiday with the Father having Easter 1998.
7. Both parties shall enjoy reasonable telephone access with the
children when the children are in the custody of the other
parent.
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JUDITH E. MATHES,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
.
.
V
:CIVIL ACTION - LAW
.
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DANIEL R. MATHES,
Defendant
:NO: 96 - 2556 CIVIL TERM
: IN CUSTODY
Prior Judge: Kevin A. Hess
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE raTH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the
following report:
1. The pertinent information pertaining to the children who are
the subject of this litigation is as follows:
Erin Leigh Mathes, born October 6, 1983 and Scott Daniel
Mathes, born April 24, 1991.
2. A Conciliation Conference was held on April 7, 1997, with the
following individuals in attendance:
The Mother, Judith E. Mathes, with her counsel, Frances Del
Duca, Esquire, and the Father, Daniel R. Mathes, with his
counsel, Lisa Marie Coyne, Esquire.
3. The parties reached an agreement in accordance with the Order
which is attached.
7
C1v~
Hubert x. Gilroy, squ~re
Custody Concilia or
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JUDITH E. MATHES,
Plaintiff
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.
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 96 - 2556 CIVIL TERM
.
.
v.
.
.
:
DANIEL R. MATHES,
Defendant
.
.
.
.
: CIVIL ACTION - CUSTODY
COURT ORDER
AND NOW, this ':1 ~ day of ifa..."o..,
consideration of the attached Custody Conciliation
ordered and directed as follows:
7
, 1994, upon
Report, it is
1. The Mother, Judith E. Mathes, and the Father, Daniel R.
Mathes, shall enjoy shared legal custody of Erin Leigh Mathes,
born October 6, 1983 and Scott Daniel Mathes, born April 24,
1991.
2. The Mother shall enjoy primary physical custody of both
children.
3. The Father shall enjoy periods of temporary physical custody
of both children one weekend a month for December 1996,
January, February and March, 1997. In December, the timeframe
shall be from Friday, December 27 at noon until Sunday,
December 29 at noon. The timeframes on the other three
weekends shall be from when the children are out of school
until Sunday evening at 6:00 p.m., or earlier if the Father
advises the Mother in advance. The weekends in January,
February and March shall be as agreed upon between the parties
and subject to Mother's work schedule and Father's military
reserves schedule.
4. The parties shall meet for another custody conciliation
conference on Friday, March 28, 1997, at 8:30 a.m. at the 4th
Floor Conference Room at the Cumberland County Courthouse.
5. r~hen Father does not have custody of the children, he shall
enj oy reasonable telephone contact wi th the minor c/d Idren.
When the children are in the custody of the Fat/lor, Mothor
shall enjoy reasonable telephone contacts with the minor
children.
6. Father shall handle transportation for exchange of custody of
the minor children.
JUDITH E. MATHES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
v. . CIVIL ACTION - LAW
.
.
.
DANIEL R. MATHES, : NO. 96 - 2556 CIVIL TERM
Defendant .
.
: CIVIL ACTION - CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b}, the undersigned Custody Conciliator submits the
following report:
1. The information pertaining to the children who are subject of
this litigation is as follows:
Erin Leigh Mathes, born October 6, 1983
Scott Daniel Mathes, born April 24, 1991
2. A Conciliation Conference was held on December 18, 1996.
Present were the Mother, Judith E. Mathes, with her counsel
Frances Del Duca, Esquire, and the Father, Daniel R. Mathes,
with his counsel, Lisa Coyne, Esquire.
3. The parties reached an agreement in accordance with the Order
which is attached.
II '3/ f7
Date
I ray , Esquire
nciliator
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, H. Ul:.L. UU"'''
ATIORNEY AT LAW
lI:N Wt.T 1111 I "1 nlU
CAnUGl.E. PENNSYLVANIA
'7013
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. .
. .
IN TilE COURT Of COlo\MON PLEAS OF
CllMUERI.J\ND COU!JTY, _lE.N~SYLVJ\lj IA
NO. 96- ,;2,~n '& C ^,v.~ ...J lA-v...........
IN CUSTODY
E. HIITIIES
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v,
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DANIEL R. HATIIES
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ORDER OF COURT
AND NOW, this .il.-'~ day of 7'~1i' ' 1996, upon
consideration of the attached complaint, it is hereby
directed that the parties and their respective counsel
appear before -I"";lj -"!.I</"Ll [''1' the ~onciliator, at u....J.tr ~.:i~<J<d.
on the cJ/!."f day of O...e.. , 1996, at 'I,JI, .;; .m., for a <'/-~ll 0/ r.?..,.
Pre-lIear Ing custody "Conference. At such conference, an ,.
effort wi 11 be made to resolve the issues in dispute I or if
this cannot be accoll\!Jlished, to define and narrow the issues
to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present
at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By 1.(1 '7'~~~J /;:/~
custody Conciliator
a
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The Court of Common Pleas of cumberland County is
required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible
facilities and reasonable accomodations available to
disabled individuals having business before the court,
please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the
court. You must attend the scheduled conference or hearing.
YOU SlIOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LI\WYER OR CANNOT I\FFORD ONE, GO '1'0 OR
TELEPHONE THE OFFICE SET FOR'1'lI BELOW '1'0 FIND OUT WHERE YOU
CAN GET LEGAL HELP.
OFFICE OF THE COURT ADtlINI STRATOR
COURTIIOUSE, 4TH fLOOR
TRUE COpy FROM RECORD CARLISLE, I'~ 17013
In Tes1lmonywhereo1.I here unto setmylw1d 717-240-6200
and the seal 01 said Court at Carlisle, Pa.
Thill ...:J/f,J day of. >II'L;' 19 ~r
Af"l ;-' pr~~~~j~:
{XI//I:Ii'/J
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NJ \,<"v
CC((J)fPlf
AUG J 2 :'996
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JUDITH E. MATHES, : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
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v. . CIVIL ACTION - LAW
.
:
DANIEL R. MATHES, . NO. 96 - 2556 CIVIL TERM
.
Defendant .
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. CIVIL ACTION - CUSTODY
.
COURT ORDER
being advised
*7 ~
6' day of .I
that the parties desire
. 1996, the Conciliator
AND NOW, this
a general continuance, the
Conciliator relinquishes jurisdiction.
The parties may file
another petition to have a conciliation scheduled.
Hubert X. Gilro , Esquire
Custody Conci ator
cc: Lisa Marie Coyne, Esquire
Frances DelDuca, Esquire
LXI-II t3 I, i:'!
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JUDITH E. MATHES, . IN THE COURT OF COMMON PLEAS OF
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Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
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v. . CIVIL ACTION - LAW
.
.
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DANIEL R. MATHES, . NO. 96 - 2556 CIVIL TERM
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Defendant I
. CIVIL ACTION - CUSTODY
.
AN!. NOW, this
being advised
COURT ORDER
'Sl7 ~
<.0 day of .1
that the parties desire
a general continuance, the
. 1996, the Conciliator
Conciliator relinquishes jurisdiction.
The parties may file
another petition to have a conciliation scheduled.
Hubert x.
Custody Conci
CCI Lisa Marie Coyne, Esquire
Frances DelDuca, Esquire
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Piano - gift from neighbor
Floor lamps (3)
Picture
Desk lamp
Desk chair
China tea set (roses) - gift to Wife from mother-in
law to go to Erin
Books
Stain glass supplies - basement
100.00
20.00
25.00
100.00
Attic
Toys
Garage
Pine coffee table
Two pine end tables
Five white kitchen chairs
Couch
White desk
Motorcycle
Tools
9 rnm gun
Grill
75.00
25.00
25.00
200.00
25.00
1,000.00
400.00
200.00
Kitchen
Table
Four cherry chairs
Bread box
Toaster
Oven
Microwave
Pictures
Pots/pans
Dishes
Dishes in box
Glassware
Refrigerator
Utensils
9 x 12 rug
Two lamps
Ivory chair - Dan's grandmother
Night stand
Wreath
Pictures
Three fig trees
400.00
200.00
20.00
10.00
100.00
200.00
100.00
100.00
50.00
50.00
400.00
50.00
100.00
20.00
100.00
15.00
80.00
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JUDITH E. MATIIES . . IN THE COURT OF COMMON PLEAS OF
. .
. . CUMBERLAND COUNTY, PENNSYLVANIA
. .
NO. 96-;L ,~'\i, (1.,,0' -
v. : : 1./'...-.
. .
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DANIEL R. MATHES . . IN CUSTODY
. .
COMPLAINT FOR CUSTODY
1. The plaintiff is Judith E. Mathes, 305 Walnut
Street, Boiling Springs, Cumberland County, Pennsylvania,
17007.
2. Defendant is Daniel R. Mathes, who has a mailing
address of P.O. Box 477, Boiling Springs, Cumberland County,
Pennsylvania, 17007.
3. Plaintiff seeks custody of the following children:
Erin Leigh born 10/6/83 in Carlisle
Scott Daniel born 4/24/91 in West Germany
The children were born of the marriage of the
parties.
The children are presently in the custody of
plaintiff.
The children resided with both parents at 305
Walnut Street, Boiling Springs, Pennsylvania since August
1993.
The mother of the children is Judith E. Mathes.
The father of the children is Daniel R. Mathes.
4. Plaintiff has not participated as a party or
witness, or in another capacity, in other litigation
concerning the custody of the children in this or another
court.
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