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Home My WebLink About00-01210 II .., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA LAWRENCE M. HAKE, VS. NO. 2000-1210 CIVIL Defendant CIVIL ACTION - LAW IN DIVORCE LEZLI J. HAKE, AFFIDA VII OF SERVICE AND NOW, this ~~ of 0/ t7~ ,2000 personally appeared Jane M. Alexander, Esquire who swears according to law, that a true and correct copy of a COMPLAINT IN DIVORCE was caused to be served by certified mail with return receipt requested upon the said, LezIi J. Hake P. O. Box 1039 Carlisle, PA 17013 on March I 1 2000 by leaving the same at the DiIIsburg Post Office with postage pre-paid thereon as evidenced by the mailing receipt and return receipt hereto attahced and made a part hereof. II ! Sworn and subs~ed before me this 16' . day of ,2000. ~ Notarial Seal Halvard E. Alexander, Notary Publio Dillsburg Boro, York c~unty My Commission Expires April 23, 2001 Member, Pennsylvania Association of Notaries p,,", III", ,", '-_-,-~.", ".,-,'t.", _ " .'- .' ~d . '"Y o...,,!, -", ,~ " I II ". ", ", Plaintiff IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PA LAWRENCE M. HAKE, VS. NO. 2000-1210 CIVIL LEZLI J. HAKE, CIVIL ACTION - LAW IN DIVORCE Defendant PROOF OF SERVICE .. I l!! ~ 'l! In 0 \.r) "fti l!! 0 tSl lr) ill r::: IJJ + \, ~ <T. :'1 :i .(1) ~ (l:- . I fl.J 'tl"5l ~ r'6 ':"lJ) 3' ~ ~ ..n CDi ~ :Eeca ... CJ t:l1.c \-) "8 "I '" fD &:i S~1jl il fl.J o m ~ j of H lU...>,S ~<>!l.~ of ." 08 c .. Er ~- -;: <;It ~ .!!li .. ,! U) Jl- 1l.E ~ ~Cl Ii] ~ .~ 2l fl.J ]I D.iij .. "..<( ~ :!l J~ -- .... ~ ZQ... BU ~ :g 21 il15 g .. [15' f i " N D..CI).5cc " '€ .. ~ HH~ . ~ s- ~a::~,gcll In ~ a; .. S66 ~ I!Jdv '008& WJO~ Sd 'ii'II!!'~.IIJ)lfl: !! ",' . Complete items 1 and/or 2 for-additional services. ct) . Complete items 3, 4a, and 4b. ;\ ' cP . Print your name and address on the reverse of this form so that we can retum'this ~ ~~~. '." ~ . Attach this fonn to the front of the mailpie'ce, or on the back if space do~~ not fU permit. ._ ':' ... . Write "Return Receipt RequestedN on the mailpiece below the article-;nurnl;ler. 1:1 . The Return Receipt will show to whom the article was delivered and the ,date ! - delivered. 1 :1 6 3.. Article Addressed to: ." Ii ~ L6~i...~ S. - I I~ o I" r ,~ I.,; liE I.- 1- " IJ. .. 1- ,~I ' I also wish to receive the following services (for an extra fee): 1 )i'LAddressee's Address 2. J8=.,Restricted Delivery C~:msult postmaster for fee. 48.. Article Number "Z 25'i' ~80 ~<;l. 4b. Service Type D Registered D ",xpress Mail D Return Receipt for Merchandise 7. Date of Delivery ..1'\""'\ ..?- //-p (../ 8. Addressee's Address (Only if requested and fee is paid) +t,4l<€ p.O. B6/C 103'1 CA~L:r SLe) PA nO \3 ~ertifiEtd D Insured D COD 102595-98-8-0229 Domestic Return Receipt ", Ii 'i>: .. Ul 'Ii. 'il .. II: c - " ~ '" c "ij I " - .2 " o >- '" c .. .c .- , ,JIIII!I!I!!Ii , >- ~. (: 9? ~ 0--: f~ -~ ~- CO ::J ::e; !---\ (:) Z --"'" "'~ -- ~::J :::j 0" >- C) ~:-;" UJ .":J Z D;: ..CZ ;.i.-li..1.j LL. a:JCl.., .oG: ..2 ~- c). ::J C) C) 0 tIl Ft: fiI ..:l p.. r... 8 Z r... Z 0 H Ft: :;: 8 0 fiI J " ~ ~ :;: .-l Z Z U ..; 1$ 0 :>:..-< H fiI H Vl , UFt:Ft:i> -Ft: r... :> ..~'" 15~~ p.. ..:l..-< fiI..:l fiI ~ - ~ 'j~~ r... u :>::p.. . 0 fiI 0 - I Ft: tIl tIl 'Ii r~' 0 0 II: :> - 8ZZ~ fiI r... ~Ft:ON . :>:: 0 Vl Q; g' D..:lH~fi1 :;: Ft: ~ ~ ~ . O~8 IU II: 8 UfilUO~ fiI . H P'Ft:oO U OJ :> fiI:;: 0:> Z Ft: II:D..:lNH fiI H 0 8UH 0 ~ ..:l H :> . '" r... Zr...HOZ Ft: fiI r... HOUZH ..:l ..:l Ft: ~ " oW ~? II > i ' " LAWRENCE M. HAKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. vs. NO. ;2fJCo-/c2 /0 ~ LEZLI J. HAKE, CIVIL ACTION - LAW IN DIVORCE Defendant NOTICE TO DEFEND AND CI,AIM 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 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. I When the ground for the divorce is indignities or irretrievable breakdown of the Ii marriage, you may request marriage counseling. A list of marriage counselors is available in I. the office of the Prothonotary at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania 17013. I II. I I 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. Court Administrator Cumberland County Court House Fourth Floor Carlisle, PA 17013 (717) 240-6222 "'F'~"'-' _",",.e., _0<. ~~- . _ '" '" ,"".F. '<~_', =. ~ ,. - > , .' !i LAWRENCE M. HAKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. vs. NO. LEZLI J. HAKE, CIVIL ACTION - LAW IN DIVORCE Defendant NOTICIA USTED HA SIDO DEMAND ADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion recIamados por el demandant. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotry, en la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFlCINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Court Administrator Cumberland County Court House Fourth Floor Carlisle, PA 17013 (717) 240-6222 ,. 1""':"'" j,< . , .< LAWRENCE M. HAKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. NO. .J.o-v-o - l:l10 ~ T p.-. vs. LEZLI J. HAKE, CIVIL ACTION - LAW IN DIVORCE Defendant COMPLAINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE COUNT I /{~ the Plaintiff, Lawrence M. Hake, by his attorney, Jane M. Alexander, Esquire, and files this /}/I/'d AND NOW, this a - day of ,2000, comes Complaint upon a cause of action of which the following is a statement. 1. Plaintiff is Lawrence M. Hake, 41 years of age, who currently resides at 4181 Elk Court, #14, Mechanicsburg, Hampden Township, Cumberland County, Commonwealth of Pennsylvania 17055. 2. Defendant is LezIi J. Hake, 38 years of age, who currently resides at I 'j 1,1 an undisclosed location care of Legal Services, Inc., 8 Irvine Row, Carlisle, Cumberland ;'1 County, Commonwealth of Pennsylvania 17013. 3. Plaintiff and Defendant have both resided in the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on July 7, 1990 in Mechanicsburg, Pennsylvania by a Minister. r. "-._,, -, c ---~ ,-~, ,. 'J ~-,> -. r - 1'-' - ~ - " c.,.~ _ ,~_~",..,..,... e,,_ ',",_, ,_, _ ,-c - "'I!l!!II!IJ!!I!I! '. ." 5. There were three (3) children born to the parties during this marriage, William Martin Hake, age 8 years, born May 12, 1991, Jacquelyn Caitlin Hake, age 6 years, born June 11, 1993, and Amanda Jayne Hake, age 4 years, born September 1, 1998. 6. There were no prior actions in divorce or annulment commenced by the parties. 7. The parties have not entered into a written agreement as to alimony, counsel fees, cost and property division. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render his condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COTJNT II 10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference and made a part hereof. 11. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. I 1-0-, - ^ ',"., _. ,~,.. " .~_ 0 . _, __' " _ _ _ "." 'e --, ,-,. " ,-,-, 1- . ~ ',~. - -'~':.- <"\'''~'''- --~~--,~ I!!!II!II!I I " '",-'- 0< "' r-o. ~:I 11 , .' ,I COUNT III 12. The allegations of Paragraph one (1) through nine (9) and Paragraphs ten (10) and eleven (11) are incorporated herein by reference and made a part hereof. 13. Plaintiff and Defendant have acquired property, both real and personal during their marriage. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property of whatsoever kind and wheresoever situate and for such further relief as the Court may deem equitable and just. Respectfully Submitted, ,11 I, - - -- < ~- -~o _ -." ,- . ~---, " -I~ II Verification I verify that the statements made in this Complaint 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: ,$ Ix /d t7170 U~Hlli4 41 COMMONWEALTH OF PENNSYLVANIA S.S COUNTY OF YORK Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared Lawrence M. Bake who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of his know led , information and belief. Sworn to and subscrijrd before me this c:J ~ day of ,2000. . Notarial Seal ~::~~~o~~~~, ~ot~~cPUbIJC My Co j' ..~., l/\ Ounty mm.sSlon Expires Feb 4 IVJ ' . .2003 emDer, Pennsylvania Association of Notarie$ ~", ,'-, I '^ , ~ - -' .- ,""'.-- >--1 .- . '- ~ ,. 1"~ "'C' ' .- I .- J ~ 1 0 ~ '"' 7S "" N ~ 5 ~ ~ ~ '" ,- :,; " \-; - ..., ~ r'6 " '" " - ...... ...... Cl' ...... ..-0> <:J- .. -... ~ .. ~-& ~. s~ ~ Ul 0< I'iI I'iI ~ 8 Q .:I ~ Z 0 ~o< H 0< tJ ~ 8 Q Z Z Z Z Ol'il 0 , . H I'iI HtJ J - :0:>< 0< ~ 8P:: '" -' (!; :0:8 .:I I'iI tJO ..~ ~~~ OZS: ~ Q 1'iI:> tJOO< , UlH ~ 0"'0 0.:1 I'iI Q E'" .... ~tJ ~ . i>: .;e~~ 0 I 0< Ul , I'iII'iI ~r~~ Q I!: :> I'iI QI!: 8ZZ ~ Z8 "'c.; ~ i>:O<O . 0< 0 ~ ! ~ O.:lH I'iI :0: I!: ~ 0i>:8 tJ 80 tJl'iltJ i>: I'iI . Z ill 0< 0 tJ i""J H~ 1'iI:O: :> Z O<tJ I!: 0.:1 H I'iI H .:1- 8tJH Q !i .:I ~~ :> . N :0:0 ;:j~H!i?;:j ~ ~ 0'" . tJ'" fr -" ~ .,:; r- ib =''1...-1: w9. 0-= ~)C~ ::::: ()f~ u_._'i! .ex: :>. !..L,...L-- Cl__J 6E5 ("') ~~9 a: u..!D- I [1.:2 :=! I.lJ "'" . "1t: u...':r: ....;( fi)~ }--. x: =:; ~- ~ C> :;) 0 CJ J '", . - . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LEZLI J. HAKE, Plaintiff : No. 2000-1210 Civil Term v. LAWRENCE M. BAKE, Defendant : IN DIVORCE PRAECIPE TO WITBDRA W ACTION To the Prothonotary: Please withdraw the above action in Divorce, which includes Counts I, II and III.. Respectfully submitted: ^~~~'""'" ~" ~ , ^'.",,:-., ,'-. 1"" I = ."~~ ," '''''-_ _,'A,_.<;_~_" "_"" _ ,_""""~",,JII1! . - IIIDl ~. ~~ -"~~ - - -1-~"" --~ o ~ -OW mil" 2',-i Zr CD- "l~. r:s :2:' ...-0 ::i:> ZO peS c:: z =< ,. .. <::> a c.... c::: ~ N <!) o -'1 :~;:J '-;-; :J] ......, {t~? ..,0 i;?~ Brn --1 1'; -< "'" :1: ~f? N <.T1 1ll#,*,~lf!'>'ij'1'-;;.,)f.~!f1~_ ~ LAWRENCE M. RAKE IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. LEZLI J. RAKE 00-1210 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 30tb day of June ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mecbanicsburg, PA 17055 on the ..!!!-. day of AU2ust , 2000, at 1:00 PM for a Pre-Hearing 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. 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 II temporary or permanent order. FOR TIlE COURT, By: Isl Dawn S. Sunday. ES~~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations 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 SHOULD TAKE TillS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ,"I,", 1iIi~ ^' "..tillliiiililHlllr~-~-' ,.,;,..~=,~..,~ 'IbL '-'!W~"'i"""'lJi'"" _ ~ 1 ,;.....;'" ,," $'. -^ ~.... ~- 1:-1LE!}-()~F;Ct 1'1" 'C' ,," ""T' . '''c''''''''AR'Y .) ~ : '"I' '-'[ ':-""0 'r if" ,:.'\i.)1 ", CO JUL -3 P1'1 12; j9 CUMBEnLA\D COUN1Y PENNSYLVANIA 7's-Of) &d. ~ M4 ~ 4 ~ >8c~t?~ ~ z; 9"~ )-3'CJa ~ ~ ;?b' ~.~ '-. !! LAWRENCE M. HAKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. vs. NO. 2000-1210 CIVIL LEZLI J. HAKE, CIVIL ACTION - LAW IN CUSTODY Defendant ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before conciliator, at the day of ,2000, at _ _ _.M., for a Pre-Hearing 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 subject of this custody action age 5 or older to the conference, but the child's/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. , the on FOR THE COURT, By: Custody Conciliator YOU SHOULD TAKE TillS 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (71 7) 249-3166 ,~ LAWRENCE M. HAKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. vs. NO. 2000-1210 CIVIL Defendant CIVIL ACTION - LAW IN CUSTODY LEZLI J. HAKE, 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 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 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 Court House, One Courthouse Square, 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 TELEPHONE i THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 I I ,...., . -. - -" -~, <, , "---,,,--. ,- "L . '"~ .. _ ,_,n'O~_~'_O ,_ ,,_ '_~_ - LAWRENCE M. HAKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. vs. NO. 2000-1210 CIVIL Defendant CIVIL ACTION - LAW IN CUSTODY LEZLI J. HAKE, NOTICIA USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compeusacion reciamados por el demandant. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotry, en la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS. 'I USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI I NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 -0__'" v ,__ , " ~ -- - ,.... LAWRENCE M. HAKE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. vs. NO. 2000-1210 CIVIL Defendant CIVIL ACTION - LAW IN CUSTODY LEZLI J. HAKE, COMPLAINT FOR CUSTODY AND NOW, TO WIT, this :)1 ~ay of 0/ ~~ ,2000 comes the Plaintiff, Lawrence M. Hake, by and through his attorney, Jane M. Alexander, Esquire, and files this Complaint of which the following is a statement: 1. Plaintiff is Lawrence M. Hake, an adult individual who currently resides at Twigg Mobile Home Park, 124 Castle Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Lezli J. Hake, an adult individual whose current address is P. O. Box 1039, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant were married on July 7, 1990 in Mechanicsburg, Pennsylvania and on March 3,2000 Plaintiff filed an action in divorce in the Court of Common Please of Cumberland County to no 2000-1210. 4. Plaintiff and Defendant are the natural parents of three (3) minor children, all were born during this marriage: William Martin Hake, age 9, born May 12, 1991, Jacquelyn Caitlin Hake, age 6, born June 11, 1993 and Amanda Jayne Hake, age 4, born September 1, 1998. 5. Plaintiff seeks joint legal custody and primary physical custody of the three (3) children with Defendant having alternating weeks of physical custody during the summer months and standard visitation during the school years. ~:--"; -.- '~I . -- "-~ -~""_A-~ - 0'. ;,,',' ' '0 I.... 6. All three (3) children are presently and have been since February 19,2000 in the custody of the Defendant, the natural mother pursuant to the terms of a final Protection Order of Judge Wesley OIer, Jr. dated March 15, 2000, a copy of which is marked Exhibit "A" and is attached hereto and made a part hereof. 7. The children are presently in the custody of the Defendant. 8. During the past five (5) years, the children has been living with the following persons and the following addresses: Since on or about February 21, 2000 with Mother at an undisclosed location in Cumberland County, with a mailing address ofP. O. Box 1039, Carlisle, PA 17013. From October 1998 with Plaintiff and Defendant at 4181 Elk Court #14, Mechanicsburg, PA 17055 (Hampden Township). From 1994 to October 1998 with Plaintiff and Defendant at 12 Lewis Lane Enola, PA 17025. 9. The relationship of the Plaintiff to the children is that of natural father. 10. The relationship of the Defendant to the children is that of natural mother. 11. The Plaintiff has not participated as a party or as a witness, or in any other capacity, in other litigation concerning the custody of the children in this or another court. 12. The Plaintiff has no information of a custody proceeding concerning the children pending in any other court within this Commonwealth. 13. The Plaintiff does not know of a person not a party to the proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 14. The best interests and permanent welfare of the children will be best served by granting the relief requested because the Plaintiff is able, as he has in the past, better able to provide for the care and supervision of the children and a more stable home environment. r: ,." ,. - Defendant, because of an alcohol problem, was often unable to care for the children when the parties lived together. WHEREFORE, Plaintiff requests your Honorable Court to grant him joint legal custody with Defendant by Plaintiff having primary physical custody of the said three (3) children with Defendant having alternating weeks of physical custody during the summer months and standard visitation during the school years. ~ - --.' "-':-- '::'-:-"'-,1 II Verification I verify that the statements made in this Complaint 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: 5-;1. Lj - 00 ~ ~. J4t Lawre e M. Rake COMMONWEALTH OF PENNSYLVANIA S.S. COUNTY OF YORK Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared Lawrence M. Hake who, being affIrmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. ~~.~. La ence M. Hake Sworn to and subscribed before me this ~ ~Y>>' day of /Y1~ , 2000. 11.,. /? ~-< ..~ / Notary Public Notarial Seal Halvard E, Alexander, Notary Public Dillsbur~ Boro, York County My CommiSSion Expires April 23, 2001 Member, Pennsylvania Association of Notaries -~--,-~'""- ;."-~'.,,,- . ,.'- --~",.~- . '-'--.'--~..~,,"-, ~ . . --,. -- -- -~ it ~ Q ~ ci >- ...:!" E; ~ ['So ~ } '},.....-: .. ::Jq: r', -.< {\ qz ,".- ---.}~ ~ '~~~ ::J ("-...1 Cr) <:J ~ ~ C'-i '.2 .;2: ~ -..' ,-~_1-LU ~ ,~. . ~;~O- --, .:,. c:) ':-J (.::) U III .0: Ul ..:l . 0...0: 0.. . Z rx, H 0 , rx, Z :;,. J - ~~..:l H 0<( q N ... ! 8 q 0 ..~ ~-~ OZH Z Z 8 U::>> 'H 1>1 III , o~O OH~ Ul.o: 1>. ::> E~" rx,UU.o: :.: >-1 Ul U .E - 0 ..:l .0:0.. -Cl ~r~' qO tr:: w ~ HZ......Z :.: 0 Ul c.; ~ ~'O:NO . .0: rx, ~ ! ~ ::>..:l......H>< :>: ::r: O~IHq 8 UUlOUO Ul . Z lIlo.o:8 U 'OJ - H Ul:;;:O III Z .0: ::r:::>N..:l::> Ul H ..:l 80 HU ~ ,1 0.. .> ~ . N :;;: ~~ff.~S :3 VI Ul 0 :> >-' U ... , ...... , ---I II ", .... , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA LAWRENCE M. HAKE, VS. NO. 2000-1210 CIVIL LEZLI J. HAKE, Defendant CIVIL ACTION - LAW IN CUSTODY AFFIDA VIT OF SERVICE AND NOW, this a~ay of , 2000 personally appeared Jane M. Alexander, Esquire who s to law, that a true and correct copy of a COMPLAINT IN CUSTODY wa aused to be served by certified mail with return receipt requested upon the said, Lezli J. Hake 694 Cumberland Point Circle Mechanicsubrg, PA 17055 on July 17. 2000 by leaving the same at the DiIIsburg Post Office with postage pre-paid thereon as evidenced by the mailing receipt and return receipt hereto attahced and made a 'i part hereof. Sworn and subscribed before me this ;?tQ'~ day of ~Z ~ /Not .~ Notarial seal Halvard E. Alexander, Notary Public Dillsbur!l80ro, Vork County My CommiSSion Expires April 23, 2001 ~ .' M,e~~~,r: _p,~~,.nsylv,~_~,i~; _~~~S~~i:tiO~ _~f ,No;t3rieS " ,~ ~'" " il , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA LAWRENCE M. HAKE, VS. NO. 2000-1210 CIVIL LEZLI J. HAKE, CIVIL ACTION - LAW IN DIVORCE Defendant <tI Cl nJ .:r Cl f'- -II -II Postage $ Certified ~ee Return Receipt Fee 0- (Endorsement Required) Cl C Restricted DelivaI)' Fee t:J (Endorsement ReqUIred) Total Postage & Fees $ Cl nJ ru Name (Please Print Clearly) (To be completed by mailer) ; s~~J.::~JkfJ@..[C'~~'!''''''''':''''~'''':/:''''''~'''''''':m: g; ". ",1.,&: __m,tJirnJ'i?lauLi?D.w",,_. Llc.t. _.."...._._.._. f'-~L:1ianin" hi ,m I f4t ....L7.D~ . SENDER: . Complete items 1 anp/ifr 2 for additional services. . Complete-items 3, 4'a,:and 4b. . Print your name and address on the reverse-of this form so that we can r.eturn this card to you. . Attach this.form to the front of the mailpiece, or on the back if space does not permit. . Write "Return Receipt Requested" on the mailpiece below the article number. ~ . The Return Receipt will show to whom the article was delivered and the date - delivered. ~. .. ".., ";; .. l2 !l !! I also wish to receive the following services (for an extra fee): 1. 0 Addressee's Address 2.15!1 Restricted Delivery Consult postmaster for fee. 4a. Article Number l: ~. Article Addressed to: o. " 4b. Service Type D Registered xpress Mail rn Receipt for Merchandise f Delivery I;S..Certified [J Insured DCOD 5. Received By: (Print Name) ssee's Address (Only if requested fee is paid) it i ii, i fi; 1 d2595-9~B-022~ .. " ~ Ul a 'm' ~ c ~ ::l ';j II: Ol c ;; ::l ~ .2 ::l o ,. "" c .. J: I- - >- G- <= , '. ltJ.\) (.l.-< R-= ~".-; co:, ~. r-~ L.:" ~ - r-. >- '- c~ "'"- -, 23if .~~~ ~~~ o cO ,.;;:;: (") ::::_1 -"-, --) ,'" {:-', ~. C'J C':"'1 Ul . .0:.0: ""Z >-=IZ p",," rz.. E-t p" rz.. Z Z H .0: o - E-t Q :>:>< Z Z "" J . :>:E-t H "" U '" .. (!; OZ>-=I .0: rz.. H ..~ ~-~ Ui:>H ->-=I "" :> 0:>:3: ""p,, Q ~ ~ o~o rz..UH.o: :<; "" e ... 0 U>-=I .0: - Ul ~t~i Q iJ:: "" E-tZoZ :<; rz.. ~.o:~O . .0: 0 "'c.; !l' i:>>-=INH,," :>: iJ:: ~ ! ~ O~~E-IU E-I U,," 1 U ~ "" . H r:QO.o:O U I":l ~ ,,":>:0 :> Z iJ::i:>o>-=lH "" H Q E-tUNHQ ~ >-=I H :> . '" rz.. Zrz..OHZ .0: Ul "" rz.. HOZUH >-=I :> >-=I .0: "",--' ..> ........ ~ ,- LAWRENCE M. flAKE, : IN THE COURT OF OOMMON PLEAS OF Plaintiff . CU/l.BERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 00-1210 CIVIL TERM . : LEZLI J. BAKE, : CIVIL ACTION - LAW Defendant : IN CUSTODY ClIDER OF COURT AND I!DIJ, this ~ R day of consideration of the atta ed Custody and directed as follows: A...; ~-,s.;- Concili tion Report, , 2000, upon it is ordered 1. The Father, Lawrence M. Hake, and the Mother, Lezli J. Rake, shall have shared legal custody of William Martin Rake, born May 12, 1991, Jacquelyn Caitlin Rake, born June 11, 1993, and Amanda Jayne Rake, born September 1, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children fran August 13, 2000 at 6:00 p.m. through August 20, 2000 at 6:00 p.m. Thereafter, the Father shall have custody on alternating weekends from Friday at 6:00 through Sunday at 6:00 p.m., with the exception of the Father's first alternating weekend period of custody which shall run from Friday, September 1 at 6:00 p.m. through Labor Day, September 4, 2000 at 6:00 p.m. 4. The Mother shall have custody of the Children for vacation from August 3, 2000. through August 13, 2000. During this period, the Mother shall ensure that the Children contact the Father by telephone on Sunday at 6:00 p.m. 5. The parties shall share or alternate having custody of the Children on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B, which shall run fran Christmas Day at 12:00 noon through December 26 at 12:00 noon. The Mother shall have custody of the Children during Segment A in even numbered years and during Segment B in odd numbered years. The Father shall have custody of the Children during Segment A in odd numbered years and during Segment B in even numbered years. The parties shall share having custody of the Children over the remainder of the Christmas school break as arranged by agreement. ~~- - . .__-n ,. {' 1 ~:f-' ..<:iIL "~" "~o" >" 'JdlIiijj ~.-l_lJll;"l'i!~:~ ~''''''''''''W~. .&. L. ,......- IliII jj ,.~I ... nLFD--OPF/GE {'~ ",- '''')(Y", 'ruJ"-,"A"y J{" ,"" I:I'/:;-',:""Ii\V.f4,n 00 MJr:; lOAN 9: 56 CUM8E!'1LANO COUNTY PENNSYLVANIA ~ . ~. ~ B. THANKSGIVING: The Thanksgiving holiday shall be divided into Segment A, which shall run from the Wednesday before Thanksgiving at 6:00 p.m. through Thanksgiving Day at 4:00 p.m., and Segment B, which shall run from Thanksgiving Day at 4:00 p.m. through the following Friday at 6:00 p.m. The Father shall have custody of the Children during Segment A in even numbered years and during Segment B in odd numbered years. The Mother shall have custody of the Children during Segment A in odd numbered years and during Segment B in even numbered years. C. EASTER: The Easter holiday shall be divided into Segment A, which shall run from the Thursday before Easter at 6:00 p.m. through the Saturday before Easter at 12:00 noon, and Segment B, which shall run from the Saturday before Easter at 12:00 noon through the following Monday at 6:00 p.m. if there is no school, andcthrough sunday at 6:00 p.m. if there is school on Monday. The Mother shall have custody of the Children during Segment A in even numbered years and during Segment B in odd numbered years. The Father shall have custody of the Children during Segment A in odd numbered years and during Segment B in even numbered years. D. MEMCRIAL DAYiJQI,Y 4TBjI.AB(:R DAY: In even numbered years, the Father shall have "custedy of the Children on Memorial Day and Labor Day and the Mother shall have custody on July 4th. In odd numbered years, the Mother shall have custody on Memorial Day and Labor Day and the Father shall have custody on July 4th. The per:i,ods of custody on Memorial Day and Labor Day shall run from 9:00 a.m. until 6:00 p.m. and the period of custody on July 4th shall run from 9:00 a.m. until after the fireworks. E. MarlIER'S DAY/Il'ATBBR'S DAY: The Mother shall have custody of the Children every year on Mother's Day from the Saturday before Mother's Day at 6:00 p.m. through Sunday at 6:00 p.m. The Father shall have custody of the Children every year on Father's Day from the Saturday before Father's Day at 6:00 p.m. through Sunday at 6:00 p.m. F. In the event the Father's period of holiday custody falls irmnediatelypreceding or following his regular period of custody, the 'Father's period of holiday/regular custody shall run continuously without interruption. G. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 6. Each party shall be entitled to have custody of the Children for summer vacation each year for 2 weeks, to be scheduled either consecutively or non-consecutively as agreed between the parties. 7. The parties shall exchange custody of the Children at the Mobil Station on the Carlisle pike in Hampden TOwnship. '" '. " '" "" I: II I I I, Ii Ii I Ii I I I 1'lJ , '~""""'!l_ 8. Each party shall ensure that the other party has his or her current address and telephone number. In the event either party intends to remove the Children from his or her residence for an overnight period or longer, that party shall notify the other party of the address and telephone number where the Children can be contacted. 9. In the event either party intends' to relocate his or her residence, that party shall provide the other party with at least 60 days advance notice so that the parties can make any necessary adjustments to the custody arrangements required by the relocation by agreement or through the legal process if necessary. 10. The parties shall communicate directly with each other concerning issues involving the Children only. 11. The Father shall ensure that the Children do not have contact with their paternal grandmother unless the Father is present. 12. The Mother shall ensure that the Children do not have contact with Karen Martinez unless the Mother is present. 13. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, orharqper 'tthe free and natural development of the Children's love and respeCt for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 14. This Order is entered pursuant to an agreement of the parties at a CUstoa"y conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE OJOOT, J. ti/~ cc: Jane M. Alexander, Esquire - Counsel for Father Maryann Murphy, Esquire - Counsel for Mother c; 1i\.JJ ~-JO -00 i.Xs LAWRENCE M. BAKE, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-1210 CIVIL TERM . . LEZLI J. BAKE, : CIVIL ACTION - LAW Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr. CUSTODY CUIlCILIATIQiI SUMMARY REPOOT IN ACCXIIDANCE WITH ClJMBERLAND CXXlN'.lY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF William Martin Hake Jacquelyn Caitlin Hake Amanda Jayne Hake May 12, 1991 June 11, 1993 September I, 1998 Mother Mother Mother 2. A Conciliation Conference was held on August I, 2000, with the following individuals in attendance: The Father, Lawrence M. Hake, with his counsel, Jane M. Alexander, Esquire, and the Mother, Lezli J. Hake, wi th her counsel, Maryann. Murphy, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date Agu-o" -3 ~C) I ~da, Dawn S. Sunday, Esquire Custody Conciliator ;;;""1 "