HomeMy WebLinkAbout97-02579
~
~
q
\..
\,.
~
~
I
\
~
\
I
/
~
t'-
~ ,
~I
~
.
Q
<:
".\
. . ,
.ro*_~_~_~~'~~_~*_*_*~ro'~~~~~~:~':~:~:~~
~. - "
~ ~
~
~.'
~
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
~
STATE OF q~ PENNA,
~
','
,',
~
w
..~
w
','
~
$
w
'.'
.r4ARYK1\TE:C~..folURRl\Y' .
..Plaintiff.
N (). .,9,7::i!.5.7.9...... Civ.U...., 1997
:1
~
'.'
~
','
$
VCl'SlIS
w
','
,rpHN J. fo\URRJ\Y,
$
. . Defendant
w
','
"
$
w
DECREE IN ~
DIVORCE~ 3~SDP;11,:
AND NOW, " '..', ........, .." ~ 19 , ,9,7, .., it is ordered and
s
s
~I
~
~.'
I'~
,',
~
decreed that "~X,"" ,c;', ,~X,., '" " , '" , , ,., , " ., ., ", " plaintiff,
and,.."...., ,y9I;1tl,y"~Y..,,................,..,........, defendant,
are divorced from the bonds of matrimony.
~
w
~.~
~
~
','
s
The court retoins jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
s
~
~,
$
w
','
The attached Property Settlement Agreement is incorporated but not
........ ...... ............ ........ ..... ......... ...........................
, )T\E\rgeP. ,1:.0. ,t)1.g JJ.ecr.e;g .in niv.ar.ce., , , , , , , , , , , , , , , . , , , , . , , , , , , , , , . , . , , . , , , . , ,
~
M
.,'
~
$
..;.~uJ-<L,,~,. .~./~ 4./kvS
~/f.~ K JQi~. ,,(.71~
/1 / f' Prolhonotnry
,
$
?
~
~
;!l
~<-~~.._-
:~:. -:.:. -:.:. .:.:. .:to:. ':'."
'. _' .:+:. - .;:.--::+::-:;;-::;; <.:: -.i;. - .:.:. - .:+:: -~.:. '.:+:: .-.:;:.'-::.:.-....:t:.~ ~.:.-~ ::.;~ '-::.:.' .:t:: .:t::' .:+:. .:~f
~
~
,~
,;;
"
,',
$
,,~
*
~
~
~"
~
S
8
I'~
~
~
,,~
~
,',
$
~
~~
",
~
w
~o~
,',
~
w
'.~
~
~.'
~
~
~
','
~
~
~
~
~
J.
~
)':'
)~
/,.-
I~
/'0'
i,
I:
,
..
save harmless Husband from any and all claims or demands made
against him by reason of debts or obligations incurred by her.
2, HUSBAND'S DEBTS: Husband represents and warrants to Wife
that he will not contract or incur any debt or liability for which
Wife or her estate might be responsible and shall indemnify and
save harmless Wife from any and all claims or demands made against
her by reason of debts or obligations incurred by him.
3. MUTUAL RELEASE: Subject to the provisions of this
Agreement, each party has released and discharged, and by this
Agreement does for himself or herself and his or her heirs, legal
representatives, executors, administrators and assigns, release and
discharge the other of and from all causes of action, claims,
rights, or demands, whatsoever in law or equity, which either of
the parties ever had or now has against the other, except any or
all causes of action for termination of the marriage by divorce or
annulment and except for all causes of action for breach of any
provisions of this Agreement.
4. DIVISION OF PERSONAL PROPERTY: The parties will divide
their personal property including but not limited to household
goods and furnishings, personal effects and all other items of
personal property used by them in common privately by mutual
agreement.
S , DIVISION OF REAL PROPERTY: Wife agrees to transfer all
right, title and interest in and to the real estate situated at
2900 Merion Road, Camp Hill, Cumberland County, Pennsylvania, now
2
July 17. 1997
~
titled in the name of Husband and wife as tenants by the entireties
to the Husband and agrees to immediately execute now or in the
future any and all deeds, documents, or papers necessary to effect
such transfer of title upon request. Wife further acknowledges
that she has no claim, right, interest, or title whatsoever in said
property and further agrees never to assert any claim to said
property in the future.
Husband agrees to take necessary steps to remove Wife's name
from the mortgage within ninety (90) days of the signing of this
Agreement.
6. FINANCIAL ASSETS: Husband agrees to transfer any and all
right, title and interest he may have in the following assets to
wife.
A.
July 11. 1997
B.
Tammac Corporation profit sharing plan with an
approximate balance of Ninety Thousand ($90,OOO.00)
Dollars.
Washington Mutual Investors Fund with an
approximate balance of Forty Three Thousand Four
Hundred ($43,400.00) Dollars.
Mass Mutual IRA with an approximate balance of
Twenty Seven Thousand Seven Hundred ($27, 700.00)
Dollars.
PA National Bank Account with an approximate
balance of Five Thousand ($5,000.00) Dollars.
C.
D.
3
..
wife agrees to transfer any and all right, title and interest
he may have in the following assets to Husband,
A, UGI 401K with an approximate balance of Forty One
Thousand One Hundred ($41,100.00) Dollars.
B. Certificate of Deposit with Dauphin Deposit Bank
with an approximate balance of Eleven Thousand Five
Hundred ($11,500.00) Dollars.
C. Certificate of Deposit with Harris Savings with an
approximate balance of Ten Thousand Two Hundred
($10,200.00) Dollars.
D, Capital Income Builder Mutual Fund with an
approximate balance of Twenty One Thousand Four
Hundred ($21,400.00) Dollars.
E, Merrill Lynch Government Fund with an approximate
balance of Thirty Three Thousand Five Hundred
($33,500.00) Dollars.
F. Dauphin Deposit IRA with an approximate balance of
Thirty Four Thousand Two Hundred ($34,200.00)
Dollars.
G. Harris Savings checking account with an approximate
balance of Two Thousand ($2,000.00) Dollars,
H. Harris Savings savings account with an approximate
balance of Seventeen Thousand six Hundred
($17,600.00) Dollars.
4
July 17, 1997
~
In addition the parties are currently custodians on two
Oppenheimer Funds accounts which are held for the benefit of the
parties children. Wife is currently the named custodian on both of
these accounts, The parties agree within sixty (60) days of the
signing of this Agreement to take the necessary steps to name
Husband as custodian on Account No. 700 7001657942 which is for the
benefit of Stephen James Murray. Wife shall continue to be the
custodian on Account No. 330 3303271609 which is for the benefit of
Joseph Murray.
Both parties agree that said funds shall be solely for the
benefit of the aforementioned children's education at the college
level.
7. AUTOMOBILE: Wife agrees to transfer all of her right,
title and interest whatever it may be in a 1996 Dodge Caravan which
is currently leased through Pennsylvania National Bank. Husband
agrees that he shall be solely responsible for any and all payments
and liabilities arising out of his possession of this vehicle,
8, SHORT TERM LIVING ARRANGEMENTS: Notwithstanding any of
the provisions in this Agreement to the contrary, the parties agree
that Wife shall have the right to continue to reside in the marital
residence for a period of no more than ninety (90) days from the
signing of this Agreement. During the period of time which Wife
continues to reside in the marital residence she agrees to pay one-
half (1/2) of the household expenses including mortgage, utilities
and groceries.
1
5
July 11, 1997
"
9 , THE CHILDREN:
A. Support: Wife agrees to pay Husband Five Hundred
($500.00) Dollars per month for support of the parties two children
commencing the first full calendar month after the Wife leaves the
marital residence and continuing until Stephen's eighteenth (lBth)
birthday, If Wife leaves before the fifteenth (15th) of the month,
Two Hundred Fifty Dollars ($250.00) will be paid that month. Both
parties acknowledge that this support obligation is subject to
periodic review and modification if appropriate.
B. Husband agrees that he shall continue to maintain
health insurance coverage for the children.
C. The parties agree that commencing with tax year 1997
and each year thereafter, Husband shall have the right to claim
their youngest child Stephen as a deduction for federal income tax
return purposes. The parties further agree that commencing in tax
year 1997 and each year thereafter, Wife shall have the right to
claim their oldest child Joseph as a deduction for federal income
tax return purposes.
D, Both parties agree to carry at least One Hundred
Thirty-three Thousand ($133,000.00) Dollars of term life insurance
to provide for the children's future security and education, This
may be eliminated upon Stephen's eighteenth (lBth) birthday.
10. SPOUSAL SUPPORT/ALIMONY: Wife agrees to pay Husband
Three Hundred ($300.00) Dollars per month for two (2) years
commencing the first full calendar month after the signing of this
July 11, 1997
6
;
Agreement and continuing for twenty-four (24) months thereafter.
Said payments shall be considered spousal support until such time
as the parties are divorced, Thereafter, said payments shall be
considered alimony.
11, TIMING OF PAYMENTS:
Child support and spousal
support/alimony payments are to be made by the twenty-fifth (25th)
of each month.
12. TERMINATION OF ALIMONY:
The payments to Husband of
alimony as set forth heretofore shall continue for the aforesaid
period of time unless terminated by the following:
(1) death of Husband;
(2) remarriage of Husband;
(3) no decree in divorce having been entered within six
(6) months from the date of this Agreement or
within any extension of the said six month period
which extension has been agreed to in writing by
Husband and wife or their respective counsel.
13, WAIVERS OF CLAIMS AGAINST ESTATES:
Except as herein
otherwise provided, each party may dispose of his or her property
in any way, and each party hereby waives and relinquishes any and
all rights he or she may now have or hereafter acquire, under the
present or future laws of any jurisdiction, to share in the
property or the estate of the other as a result of the marital
relationship.
14. SUBSEOUENT DIVORCE: Both parties agree to execute all
documents necessary to obtain a divorce.
7
July 11. 1991
15. BREACH: 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 legal
fees and costs incurred by the other in enforcing their rights
under this Agreement.
16. ADDITIONAL INSTRUMENTS: 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 that
may be reasonably required to give full force and effect to the
provisions of this Agreement.
17. MODIFICATION AND WAIVER: A modification or waiver of any
of the provisions of this Agreement shall be effective only if made
in writing and executed with the same formality as this Agreement.
The failure of either party to insist upon strict performance of
any of the provisions of this Agreement shall not be construed as
a waiver of any subsequent default of the same or similar nature.
18. DESCRIPTIVE HEADINGS: The descriptive headings used
herein are for convenience only. They shall have no effect
whatsoever in determining the rights or obligations of the parties.
19. MUTUAL ACCEPTANCE: The parties accept the provisions of
this Agreement in lieu of and in full and final settlement and
satisfaction of all claims and demands that they may now or
8
July 11. 1997
hereafter have against each other pertaining to this divorce
proceeding,
20, DESIRE OF THE PARTIES: It is the desire of the parties,
to amicably adjust, compromise and settle all property rights and
all rights in, to, or against each other's property or estate,
including property heretofore or subsequently acquired by either
party.
21. TRANSFERS AND PAYMENT CONTINGENT UPON THE ENTRY OF A
DECREE IN DIVORCE: It is specifically understood and agreed by and
between the parties hereto that any transfers, documents, and the
provisions for alimony and support of Husband and the children as
provided herein are all made contingent upon the entry of a valid
and final decree in divorce.
22. INDEPENDENT SEPARATE COVENANTS: It is specifically
understood and agreed by and between the parties hereto that each
paragraph hereof shall be deemed to be a separate and independent
covenant and agreement.
23. APPLICABLE LAW: This Agreement shall be construed under
the laws of the Commonwealth of Pennsylvania.
24. VOID CLAUSES: If any term, condition, clause or
provision of this Agreement shall be determined or declared to be
void or invalid in law or otherwise, then only that term,
condition, clause or provision shall be stricken from this
Agreement and in all other respects this Agreement shall be valid
and continue in full force, effect and operation.
I
July I'. 1997
9
'.- ,.... 'r-
ei: Li: I,:
j:-- ('.~
,~ .
1I1'c_
(1"
{>O'
J_ . ,~
(5':
. ( (~J
OL I
u;' ,
~-!I , C, ,
U.' -' Lu t:::._
I - v: ,
,", r- .
U CJ~ 0
-..'
5. Plaintiff avers that there are children of the parties
under the age of 18, namely:
Joseph Murray, date of birth,
09/27/90; and Stephen Murray, date of birth, 07/31/94.
6, Neither Plaintiff nor Defendant is in the military or
naval service of the United States or its allies within the
provisions of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
7. There have been no other prior actions of divorce or
annulment filed by either of the parties hereto.
8, Plaintiff has been advised of the availability of
counseling and that Plaintiff has the right to request that the
Court require the parties to participate in counseling.
9. The marriage is irretrievably broken.
COUNT I -- CLAIM FOR EOUITABLE DISTRIBUTION OF
MARITAL PROPERTY UNDER SECTION 401 OF THE DIVORCE CODE
10. The averments of Paragraphs 1 through 9 are hereby
incorporated by reference thereto.
11, Plaintiff and Defendant are the joint owners as tenants
by the entireties of certain real estate known as 2900 Merion Road,
Camp Hill, Pennsylvania, which is subject to equitable distribution
by this Court.
12. The Plaintiff and Defendant are the owners of various
items of personal property, furniture, household goods, and
furnishings acquired during their marriage which are subject to
equitable distribution by this Court.
2
13, The Plaintiff and Defendant are the owners of various
motor vehicles, bank accounts, insurance policies, pension, profit
sharing and retirement plans, and other tangible and intangible
personal property acquired during their marriage which are subject
to equitable distribution by this Court,
COUNT II -- CUSTODY
14 , The averments of Paragraphs 1 through 13 are hereby
incorporated by reference thereto.
15, Plaintiff seeks joint legal and physical custody of both
children: Joseph Murray, age 6 years, and Stephen Murray, age 2
years,
The aforementioned children were not born out of wedlock.
The children are presently in the custody of both Plaintiff
and Defendant. During the past five (5) years, the children have
resided exclusively with both Plaintiff and Defendant,
16. Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
17. The best interest and permanent welfare of the children
will be served by granting the relief requested.
WHEREFORE, the Plaintiff requests the Court enter a Decree:
a, Dissolving the marriage between Plaintiff and
Defendant;
3
~ ~
. V>
>- eX) ,. ~ ~ l..;
o. ..:> -- '- .
t:~ - t) ....
~. c:-. ' .'1" '0
LLJ~ - L"
(.)..- :c I . ~
u-:\ :-:-
" i.l.. ::~
o{
t .:T ~~
cf
U.!l' ',.'.-
~..I( . .' .~,..
:- 'lll~1
L'; ".-. 2~ ~
>- .,- "
u. r- ~)
0 O' '-' ~
J~
.,J 'l'~
of)
....
"'l ~J
'>l.
I'()
'\)
\0
~
'- ...
~~
",,'" r--...
~I'-- ~
~ ~
~
Jb~
>-: c:'
,,;- C
,
I ~-
1.:.1 ~ ~ ..
~,~ ( - --
l,l~ ~ c.... J
II,!
y( /'..) ; ,
C' .,
1:,'- ('oJ
, :-; c ;
u.. " .\....
~. .,.
11- r- C_)
L) O' ()
{
(
.... 1-' >-
i- Ir. I:;
.' -
"~
1-" : ~, .-~
(") ,,;
UI.'.
<.', .~
rtl, \.'".4
1.1.:' ~' ...
(~) ~..: G:.
(~):..~
UJl I
__I,. e... .
U:;' ,...J :.:1i..~
i.. V)
lO. r- _:,
0 c~ W
)
)
(
l
~~.
. .
. .
. ....... _ . ___~.--'._. .~~ '4__" .>. - _. . - .._ _ .. u '.
THE LAW fiRM OF
KILLIAN Be l.:>~rffii(tH
'~-:-, . . j
CERTIFIED COpy
218 ~NI .'REEl
P. O. lOll: 888
HARRISBURG. PENNSYLVANIA 1710B.OBB6
MARY KATE C. MURRAY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 97-2579 civil Term
v.
JOHN J. MURRAY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE/CUSTODY
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on May 14, 1997.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) 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.
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.A. Section 4904 relating to
unsworn falsification to authorities.
Dated: September 2, 1997
laintiff
i~ 1""- (::
"'-: ,
is .. I .
u.!C' ,..-; , .
.
eye-. 0'- .. ..
\{~ :; '-'- ~";~
CI:-- c' 0-:', en
(~i , ,
1.1..:' I .. .. .
:-;t CO' I , ~ j
". ".-. -"I ..
;- c:./~
u. r- .~]
C..; 0' U
THE LAW FIRM or
KILLIAN Be GEPHART
. ..
aiD PINE .'AEEl
. .,
CERTIFIED COPY
~..~
P. O. DOX .,Ie
.-
HARRISBURG. PENNSYLVANIA 17108.0886
,','",,"'.:.>
.",_."r.
,. ,",'.-'
MARY KATE C. MURRAY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 97-2579 Civil Term
JOHN J. MURRAY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE/CUSTODY
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on May 14, 1997.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) 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.
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.A. Section 4904 relating to
unsworn falsification to authorities.
Dated: September 2, 1997
.'"
THF: LAW FIRM OF
KILLIAN Be GEPHART
. '.
,
t
all "IN I: .'''EEl
CERTIFIED COpy" ·
--.:;;:;"
p, O. BO. ... t:;...--t;;J
HARRISBURG. PENNSYLVANIA 17108.0886
MARY KATE C. MURRAY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 97-2579 Civil Term
JOHN J. MURRAY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE/CUSTODY
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER S3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
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.A. Section 4904 relating to
unsworn falsification to authorities.
Dated: September 2, 1997
plaintiff
::0- f"
1::: lJ
;~.
'" " C.-:
, I
': .,
j. ,-
Y' "
; ,.
cj C::l
L' i' I - ,
,-
u: , t:_ -
l' , " ;
,. V. M'~
I ,. r- -,
0 C"- ~.l
THE LAW FlAM 0'
KILLIAN Be GEPHART
. " .
CERi!:II.1E2.FOP'l .
all PtNI .,'t.CU_ ~
... 0 DO. ee.
HARRISSURG. PENNSYLVANIA 1710B.OB86
MARY KATE C. MURRAY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 97-2579 civil Term
JOHN J. MURRAY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE/CUSTODY
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER S3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
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.A. Section 4904 relating to
unsworn falsification to authorities.
Dated: September 2, 1997
Joh
'>- r-' --
"
;~ u-: ,."
~~..
i;:: .. "
.."
UJ\ .' , . -1: -
("..- .
U:~;.' , "
l.~ , :.'
8r '. .
,L .;.:~, >-:
0" I - ..
UJl_1
_I, c. " ,;.j
U:-" \.I \
I' CoO .-.
l'. r- ~-!
0 o~ \.J
MARY KATE C. MURRAY,
Plaintiff
IN THE CCJRT OF COMMON PLEAS OF
CUMBER~~ COUNTY, PENNSYLVANIA
v.
No. 97-2579 Civil Term
JOHN J. MURRAY,
Defendant
CIVIL ACT:ON - LAW
IN DIVORCE/CUSTODY
ORDER
AND NOW, qu' , upor. consideration of the
attached complaint, it is hereby directed that the parties and
their respective counsel appear before tli ( hCl e \ t ,~(l()Cl \ F<n" the
conciliator, at 3(\ A 1.\' \ ~ \1. ___">t-, crffif" l:bJ I: : Plv.. I \:
on the ,~'-\ day
of ,1......1 , 1997, at \(y (X) C\ .m. for a Pre-Hearing
Custo y Co ference, 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 childre~ 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: 'rru~.ofY;' ~-NnM(~
Custody Conciliator (~) If
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
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 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 Admin~strator
Cumberland County Courthouse - Fourth Floor
1 Courthouse Square
Carlisle, Pennsylvania 17013-3387
Telephone (717) 240-6200
13. The Plaintiff and Defendant are thp. owners of various
motor vehicles, bank accounts, insurance policies, pension, profit
sharing and retirement plans, and other tangible and intangible
personal property acquired during their marriage which are subject
to equlcable discr~bu:~~n =7 :~lS ::~r=.
COUNT II -- CUSTODY
14. The averments of paragraphs : through 13 are hereby
incorporated by reference thereto.
15. Plaintiff seeks joint legal and physical custody of both
children: Joseph Murray, age 6 years, and Stephen Murray, age 2
years.
The aforementioned children were not born out of wedlock.
The children are presently in the custody of both Plaintiff
and Defendant. During the past five (5) years, the children have
resided exclusively with both plaintiff and Defendant.
16. Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
17. The best interest and permanent welfare of the children
will be served by granting the relief requested.
WHEREFORE, the plaintiff requests the Court enter a Decree:
a. Dissolv~ng the marriage between Plaintiff and
Defendant;
3
,
.J
1
THt LA.W FIRM OF
KILLIAN Be~EPHART
" ---.J
Jla PINE .TAUT
P. O. 80. ..e
, CERTIFIED COP.Y
HARRISBURG. PENNSYLVANIA 17108.0886
.:"-.
~ .
. . ...;,~.
"."--....;."""'-~-~...- ,'- --_.._~-..'::";"-",,,
MARY KATE C. MURRAY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 97-2579 Civil Term
JOHN J. MURRAY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE/CUSTODY
PRAECIPE
TO THE PROTHONOTARY:
Please withdraw the count for Custody in the Divorce Complaint
in the above-captioned action.
Respectfully submitted,
')
"
Dated: July 21, 1997
Hel vy.,' ,Esquire
i11ian & Gephart
218 pine Stteet
P.O. Box 886
Harrisburg, PA 17108
(717) 232-1851
Attorney I.D. #53148
Attorneys for Plaintiff
~ ('oj ~
,.,: lJ':
1--,
IUQ ..
u-- l'" r]~?
rl:~'} a:
lL ..j~
0'- 1~":
60
".'. l"') ,,<::
. .~ .)t~0
WU N
_._1 ,;,2';
u:u: :='
.:c ;~ii't
l~" ::-; !.\~a.
~ r- :5
CTl U
,t~f~;:\',~:~lr;;?; '0;'?~;'(~~ i?~~~;~ ;('~~~({_::~~~~j: ~wJ!:~r'!' 4~"-;:: ,?~~);,. :q~ ':.'N"':<'r'-]' ,,,",..,,,. ",,",' .' .., .,
..\..', .. ,...., ".. ....,,,.. 'lJ:1"!;1...,'..'...' ...." ,~,\,....u,..,."".<.;Ji\ii~'lt"!1.\'l'Jl"'."',ij"". ,
, , ", ,'ii~ ",,,:'\1:';C:"~~!f( ,J;i'll~
... " ,: ......."..,.,','0..)r:t.~" ,
~ .' r,' ~, \ ~~;,.J.;jk'< ,:~+-'1G~kj .
, _. !::'.';}..'t\;;~;;~),,,,;,:-c#t'1.'>t-"".
'<{:.~~:.,~ ~.~ ~': ':.'1',:
'- C':J /
C'; ('.
.
'-, "J
Ill~
~;~.~. ~ ,
':ii
L, .., ,
. "
Oi.
UJl .
E:'! . (.'-; ~ i:!
'-lLl..
i ... ~ ,
", r- ..-'
C> '" u