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OCT ! 199~,c)--
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II/I'NE/IIAR/E ROSEMARIE COltlJ>EN
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IN TIlE COURT OF COMMON nFAS OF
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CiJMBERLAND COUNTY, PENNSYLVANIA
cl'~/iL AcrioN - LA~\'
.TN ~DII'ORCE
No, 'l'J. .-d8 f/5 cll,iL TeRM
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LAWRENCE ""ILL/11M CPH.'JJEN
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I, 'RE:SPONSE TO THE O'RDER FOR RilLE TO SHOW CAliSE - AND
J[ . CONTEST ()f= PETiTioN BY mE' l'FIJN S171-n: 1II-1iilE/?SfrY-
:DieXt/JSON SCHOOL OF LAW - r't1Mii...y LAW CLiNic. FI)/~ LEAVE"
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TO WITHP/V1W FR.OM Tilt;' ABOVC 'RFFE'ROVCElJ CASt: PURStJl1/tff'
Tr) 'R ()LE d..l6 (b) (3) AND (If) OF mE 'R ilLES (J~ PROFESSIONAL
eONDUCr:
7iJ 71fE H())/OR.AolE', 77fE JUJ)t;ES OF THE SI//j) C()flRT:
NOw COMES 71/E, ,i.! Tlfl!; ACTlt'N '8'1 TlIe FAAI't...Y LA/~' czlNic RE'F~[;])
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7lJ AS PLAit./TlFF I AAWE/lIA~/i: R{).st:IIII1~/i;: C(ltr/j)o.: I BaT ,1IH(J /5 AC7ZIII"-Y
111" NAM"lJ ']JEFo.,PANT I IN '11ft; 11/J(!1'!:' 'ReFr~o.;c..'Q> CASE IN ])IVc-RCE'
NO, 9'1- ;2.3'/.5 i!>J:,tllGHT AC;,4/).'Sr lIa BY mc lf~EI~ ANlJ 11/'0('11:
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IHE FCt..LOH'/I-./I'!.. 'R/;;':;'''(ltJ.~;C T(> SHP/ti CA/.I..~E' IVItV TlfE;' FAlJ.1ll..,/ /..IIW
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~ Ulvic.. SHfJUI-D NOr pC {}/:.A/..'TrP LeAVE TO 11I1TI/})KA11I AS (-{ltlNSt:"L OF
'F,ECORJI - II/I/D ff/;;~e8,/ cOA'(7;:SiS TtIO~PenT7C/IJ FOR Le-AVC rr 1~'/TH'p;:A~\;
BASCD ON TH~ ~UU:,<; eJrr:::D Af'>('I~ - ,4/y}) KeSlttTFULt.Y 7<C?RcStNT.S:
A. ,HAT1 17ft;" FAM,LY LAt" LI-I;...'IC HAD 1/vt'TtA/.L-Y IJff€'tUl> TO RD'~~Se.T
HF:R, IVHa SHe" CA/'t..Cf) T1-/tdR. Lllh,' L'-BRARY IN ..sc-f'mlBD~. ,1'/C/7-
WiTH G.ut;ST/('N,"; A8<./lr U:GAI- Tl7'JtI.':> I E:TC" /JuliE ,4T71D1tl'TlNc;. iP
'R.EPR{;'sexr HeJ~nF II <; />;('1\ AC(-n//>,' /./NA8lC n IIFFt'R./J IIN ATTli/:/./E:'//
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N~, '11 '-;U? '15"
AN/) WAS 1I.$I(~b To DrPLlIIIJ HeR {'Ase S/l7IAritW,
~. THIlT, AT m€' n;.tc. (JF me INTAKe' INrc;~V;Elv w/m nft;: FII/lf,'LY LAtll
C.lIN/c. ON 77/~ AOT71 vF scpmll3tR. fi'197, SHe HI/ll TlIIWtt'll Ol'O!. TOme
.5TUlJOVr ATroMcy ANI> ntt:}:$l'>Y 'TV 711(;' FA-nlllY L4tL' {.'UNlc - O'ay WCL/-
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ltlllS 111..5(' IJ Ct./,Y OF IIQ<.. iNiriAL.. O~c.T/ONr() 71IE COllI1'l../WiT III
:DiVOR.CE/ Wlliclf $Ht:: IMD FtLE]) tliTH YClUe H(,NO~AI!>Lt; eOil!!r;
()1=1="'t'~ OF TIlt;' PiU'TltCNtITlIt?Y, (W THe ;?3R.il bFJ/lN!: .1997, w/rHTlfllT
Ol3.%Cn (tV I SHe]JiD NOr 05Jrcr IN ~S.5 eN L.'C ro BC/Nt;- l>iVMCC.D
FI!.CII1 THe;: ABove R.€Fa~c.D 7lJ J)r;-FoJ.iJAA'r, 'BLJT St'll/flti TO '])ES-
Ct:-i8r; FM. Y('tuz.. HrJAl(;~AblJ;" C(?t<RT'.5 II TTEJoIT/bN HGR ()IUJeAL OF
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Hc~ MA~;:'''Ac;.r; Ivim 71ft:' ,T>!:FWJ:>ANT /lND Hfi:.. c;~/fi J)islUJ VIIN7lICif;
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IN mt" .DCF€N.J>/IA/T Bt"INt; Q-RAN7TP A alae/< NO-FAULT '])/VORCE
/lIP If! I fI Fl7m.. E'l' A l>i,.f(l- AN j) A v C'I'.!> /Ale;. Him. -p iVORCE - FoR - Fllu t..T
ACTieN - C IfSt" NO, F, R, fitJ71-S2;' -])- 11, I'. ,')'1. iN Fl?l/-lI/KLi/l/ ClJuNT'j/
'PItNNsyL VII-NiA I AGAi'NST HiM iN /1'779 (;1980) FO/? .,f8 YD1RS/ BY
l-/ipltJ<f- iN /IN]) OUT OF ,':o./1/7E"'INaLw/N<!. His ((WTlNUCD pt:l<.veR.TED
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t..iFcsryU; IN ADULITRY AND THr;JU!P>Y DE7It''N.s7~ATE"D AM;E1\'C:€' ()FSHItIl1E"'
AN]) -1!.ESP€CT FOe. TIIr;- INSTiTUTioN (IF AtARRiAr:;C, IN TlMr tJE'VtCT-
iON SIft: II-l5(' ~/'/'ClU.ClJ 7(1 yl'tl!-:. HflNC1:./ll3lC c{)UR.i Fo/2. W'ltZ.
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e.'WS,DC!2.An'cN FCt:. /fa / FOtC- AT LClIST F/N/WC/I1L. SVI'C/i:.r
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!:SPt;C/AtL Y, .<;t"./CE i71t: DEFo./ D/tfoJT NEVER. !11AD!: liNt St(C'H CrN';--f:/-
13tm(tA! -, n' lia .SINce JX:.::n::..n;""c; Ifr;-I!.. 11 S/~'TH IIN'.i) ANAL- 7Ilne
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3. iHIt"0 /N FULL tiN DCIZSTlIN DINe;. OF THf: A6t'l't:" 'Rt;Ft;'XOJCCD
'PLAiNTiFF'S ,IN;F:R';:ST iN liP/VORCE', 73ll T ALSO iN ,4 CfJNTI2.il3tlTlJI:.Y
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FINItNCIIIL- /I1111N'TENI/N'CE Ft)f:!II/;'F:.1 Be IrClILL(7) ALlillCWY, F.eclll
11/t; Hau;i,,/ NIi'Nt;/) T>CFDv'::D/f-A/G wiTH /fER. l'>13T I/I/ro:&ST IN AIIN/>"
ON SD'TEM8Q:!. 30m 1..-1"197, nil; Ft11l/tLY LIfH' cLINic.. EVE7>/
F/iE/) ON HE:'R aEiMLF A "'PlE'nnfJN RR At./MONY IN YWR flONOli?ABLE
tOLLRT, kNowiNq. FULL. ~11E:u.. (IF H€R.. FCC>Non.,ic. 7)/SA])VANTAt;t:;
7H1rT oS/+(; 1i.:.lJ(;l:!> FP;e.E:{-1/o../T I:CiW?,'MIC (lPf'(),eTflNln't's Fee HCRSElt-i
1I11//,Nc; HAD It' ae Tltr; Pl2lilflll: y C~/i:.t; TAKk~ 1M//) "PCN THE HD!EI'N
N/nl1fzJ> :Dt:FCN/>A-NT'S Fi,,/AI- .])csaUlrNliv' NC//0I1I3oz.4'1"1'11 tl'AS T/lFSC'I-E"
c:./lR.E"TAI{a tlF Tilt;;" "PA;::'T/~ six (~) Ofll...])7?EN. Sift: Iv/fS ?.ewEN1ClJ
F~#J/ Fllt:.Io/IA-'1j A Fila h/oRK-l.JFt:: iN SCJC'/iIL S€cu1217V 8E"N~Frrs, HeR
t.1V/N fi- CON]), TioN-S ,'N POI'E'I<.TY, FN< n1('sr (iF THe YE"IIR.S (OF AM/02l!.iAr;c
NITH TH~ HCU NAIIIC./) JXPo.'])/lNT1 WE'RE" 'l3I:.CiiQH T t'N Ht;'R, /IN./) /-1m
CHil.j)R.1:.7I! l!>Y THC ])EFo'::t>AI'v'7!.5 (jt.n,j 11-1,4f!.117lL- /ll"SC'(JII/J>l/c'T IINlJ NE(;--
LEcr /IN-i> HE AI3I1Nj)CN~j) TItt::n1 Te: 77icSF CliNPITtCNS, NCVE"R PAYlivr;
I'lNY C'F 7'H{;' c.Ctl/~r-()~/)E"RCf) S'uPPC'l-!,T EV€N, Bn:;:n"Io.IA.'t;. JI-irH
ftlA-/2CH (IF "f'i7-.f. Sffe IIIJS NellER ACCO'7t/> TIf('S[" i.iv/A,'(/! (~,,:j)/71'c'NS
11./ PcWCR.TY AS L./I'II\'Cj STl/II,.])I/R.JJ r-c;e. 11C7~ CHILl>R.t;N OR HERSELF;
AS T/-feY Iva!.!: T/iE:'j)iRcCT CCII.'Se(\ul!7l.'('C OF THG,7JFFl:NDANT:S
FIJ'" L(!:.C III.' D 11141-.' TeN Nt;'(i LEer TO PIU'I-,'DE" 'f'H()'Pl:RLY I1N') :JJEcEN7I:f
F.cR. in:5 FAIl-lIt..y, IINlJ ~'iflC hAS E'XPt:/;,~)CD HeR. 7J,'S({"NiF^/T './TH
IT MP/ooY nA/([S o,'rn TC THE ])EFC;./l>tfll.r 7it{i!.,'utj-HC'tlT 7/-tt; Y€li!:.~,
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r#Trl!.~sr.5 II./$T1!:A]), THE" :I>t:FE:N/lANT Ifffili"lN (,~(lr (J~F ON l'A ViNq: His
DLcES Tl' His FI/MILY /ILl.. THe 'feARS ,- lIentllLt Y $INCc /97,1 /lLR.E///JY
/lND NOItI WANTS TO Cirr (JFF All-AIIV IlIiTH NOT "PAYIIJq. His wiFe A
LAST 1>eCt:'NC'Y rJF A r LCAsr A C(WTIC./BII77fRY MA/mrnv.4-NC€ to
G/l't !fE'/?. liT LrA.sr S(!/I/{;" eC(.;A~M/C .5ECilI!;-ry N7Jlv /IN/> IN O/..lJ€R.
AC,t: Yli"r ESPCO/lLL y, - SHE :J/lST SUR-I','VCD A ~AR.Ct\!. FC'R,M (iF 13REMT
t!ltNcER (INFL/lllltlIA7VRY CAR.CIf..I71IHII) (IF II FAST /ofEi'T7ISTI/c:.iz:iA'tI ~/iJ[) ill
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2JIS~ASt: /IN]) ':/)IABE7"ES I J'N,'lLIbiiv'tr OTHer... 1!E"LATE/) /!ILllf(;;}Jrs,IIND\1>f:8ILI-
1l1riIJq ])cc;.o..'E.RAnVc /lRTHtelTIC c(w"irt'cws, J)IAQII/TJSFD liv THE' LAn- /"l7f-s
/lL/U1lJ)(. HO/V tl-/~ CH LCNC}f:iC. .sHt:" CAN U'ol!K tlNl>n<!.. THeSE Ht!7ILTH
J>,c.<,'SU7I/S, AT IIGe- 57 YEII/:.S NOtv, PC-P(;"NlJS (IN 77tfDll AN/) HC~ c/,/t.y
INC('ME /'s :vn'€'NJ>t;Nr OIJ THAT reo, liS'S HAV,NG- ~N/l BEIliN; I/llLe
TO PAY Pet!. Hlf7ILTH rNSit" I/N CC I HOlLTlfCARF /lND /l1ClJ/cllnCNS-B6INcr
ON 1:.E"sr_,,~ -Lt'n: T'l:c.sa:.;rn'tws. -IT i.5' IIJ CCtllrRCHGNSiBtr TP mls
7'llll'NTlFF U/;"t:.dN, H(/~' nt(i' Pt1nllLy LAlLI CliNic CAN CI/t.L HE"IZ.. C('((fII'TV<
Cllli1l1 F&~ MAI'NTO/AtI/c.'E "I/rlPRt./JJENT11 - I<Nt'MtJ,,~ CF ,tI1-1.. me
1iFt'~c J)C'Sc7<Il3€7J (.'II!.Cl/lI/S77/A{'(;S /IN/) filZ"1?. S/T/fAT/CN,
If, THAT/ Tile FItNIL.Y LA-111 (tilu'/c.. ':101 C(TVI3l!7<- '(C/97- IIAb ~E-
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ilJ !f])lJinCN I II.; /1'/11-1;:[/1 OF ..1'79<5' AN/) (!C'/IIPL/,"j) WITH, fIClv6l/EIL 71ftJ
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ONLY W -.2 FM./I1S FC.e -199'1- AN}) ,//995' (~F IvllleH ;}NYtiA/C CIIN
/f#v~ X -NUMBE7?.. ItNj) A/'~ PIi:.[(lP CF IfllMT 1I1'1l'llNT-S Nrn.~ ])CCl./lI{(;}),Ij
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Ihf<-l:/N I .rar-.y W BUIf/N I e-saWRE', STI/TINe;- THAT TH," :/JE"Fm))/}NT!s
t'1If!.N/NC;S FeR. ..I1'lv "~__ t~'~ iN THt;;' /'l'lS 13;1LLPAR/C._/: AUNt;-
WITH /l ~,"FCf(:.mCC P,Y /-1;11/ OP Tllt;;' /f1J'.r/N JJCPeNJJANT \\ /tIPT
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'J?li'Spcc.rFtlLLY SUI3/l1/TS I THAT THe PLAiNTI'FF I9N71 Ht:1:. six (~)
(Hit../);::~ 1-1IEn.C R:,c('{;D 77) .sCIUJPr; /IN t::x/sTENCE'iN lJrrtR.-
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.st'me, /IN/) TIfAr, .iF" Tile Hl:7i!.ci/l./ Ui:FliN.lJI1/1,T NOlv LIIMav'rS ~F
'B1i//IIcr iN THAT /...OT/ He S~Ut...lJ kN'(JI~' !2fAI /0 Be LINK~lJ 'TO
His Ott/Ai :BIILJ CNe/c.:; II-/I,'j) J;JFcisl(:iJ,S rot<. Hlil1SELF AIJ.b I-ICN
TIleY /lLS(I IJFFarcj) IflS IV/FC - 7JrC HGIUIN 'PlIIINT/FF- AN.b TH~i~
CHILPR.t:tJ, /lNLJ S/H'lCL.l> N()T .sm~'{; 7D E'KCttit 1-/I'1I1,7l/C: /ftllEIIV
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wiTH PIWLiDilv'q- C('IIll'Lnt I. R. . S, RIi'CCR.DS WAS Ft'~u,4lUJE1) TlJ 17Ie-
n7TfJ~./I':t:y (IF n,t; .T>/!Tav'J>/l-Nr HE.IXIN, If) J)1tTF: NP7HINfi- HAS 8a7o,/
?cctdvcp 8Y 771E" !frr...ciN l'UI/1v7iFFI TO VIE:J.'. - IN 77rlE"' IIFle/Vl{II71i
OF THIS /t/J I> THe- I/SS,(;!J MCIv'r IJF A NClo/ .snf~CNr A TI7.eIl/E'( 8Y
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NOTAAIAL SEAL
UNllA L BERK. NolIry ~
t.ancaslIr,lJrlCIIIIr eo.nr.
My CommIalDn ~_ 24, 200Z
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SEP 9 19~~
'lj
ANNE MARIE COWDEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
LAWRENCE WILLIAM COWDEN,
Defendant
: NO. 97-2895 CIVIL TERM
ORDER FOR RULE TO SHOW CAUSE
,o-rh
AND NOW, this day of September, 1998:
(1) A rule is issued upon Anne Marie Cowden to show cause why the Family Law
Clinic should not be granted leave to withdraw as counsel of record;
(2) If Anne Marie Cowden wishes to respond to the attached petition, she shall file
an answer to Petition within twenty (20) days of service upon her and serve a copy of her
answer on the Family Law Clinic;
(3) The petition shall be decided under Pa,R.C.P, No. 206,7;
(4) Notice of entry of this Order shall be provided to all parties by The Family Law
Clinic.
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I verify that the statements made in this counter affidavit arc true and correct. I
understand that false statements herein are made subject to the penalties of I 8 Pa,C,S,
sec. 4904 relating to unsworn falsification to authorities,
Date:
Defendant
NOTICE: If you do not wish to oppose the entry ofa divorce decree and do not wish to
make any claim for economic relief, you do not need to file this counter-affidavit.
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IN THE COURT OF GOI,Ir.10N PLEA:; OF
CUl.jBERLAND COUNTY, PENNSYLVANIA
LARRY CO'IIDEN
Full namel
LAWRENCE WILLIAM COWDEN
Plaintiff
vs.
NO. 97-2895
CIVIL ACTION LAW
ANNE-MARIE COWDEN
Full--namel
ANNEMARIE ROSEMARIE COWDEN
Defendant
IN DIVORCE
OBJECTION TO COMPLAINT IN DIVORCE
As the "Defendant" - named so in irony - in and by the Complaint in
Divorce, filed against me on May )0, 1997, by my legal husband,
Lawrence William Cowden, he having the audacity after all, to present
himself as "fault free" and as the "Plaintiff" in this action, through
his Attorney Jerry Brown, )105 Old Gettysburg Rd" Camp Hill, PA 17011
- I am filing this definite objection, because there exist certain
significant unresolved issues between the two parties.
May it be knovm to your Honorable Court, that the Defendant named in
this action, does not have the means to hire an attorney, due to grave
socio-economic conditions brought onto her and her six (6) children by
the Plaintiff initially since 1971 already, not excluding prior inci-
dents even, by his actions and or inactions, causing serious consequenc-
es for his wife - the Defendant named herein - and her children. There-
fore, the Defendant has no choice but to represent and defend herself.
Your Honorable Court needs to know, that the Plaintiff has in dishonesty
misrepresented and omitted certain facts in his 10 (ten) point Complaint
in Divorce, to make the two parties marriage appear as just simply
'irretrievably broken', not to have to accept his total guilt and fault
for that fact and to obtain now, 18 years later,after his last desertion
and abandonment of his family, a quick self-suiting divorce.
The marriage between the two parties began legally on February 18, 1965,
in Berlin-Zehlendorf, Germany - and became irretrievably broken by the
Plaintiff in this action, Lawrence W, COWden, over the course of at least
- now 26 years, of the two parties' now )2 years legally existing mar-
riage, during which the Defendant in this action has been his ever faith-
ful yet injured wife, by violating his marriage vows and the laws of this
Commonwealth, prior also of the States of Ohio, North Dakota, Oklahoma,
as of any civilized state, with such indignities to his wife, he now
claims as the "Defendant", aSI Among others, repeated and continued,
even multiple and deviant adulteries, wanton conniving, conartistic dis-
honesties, gross irresponsibility, gross neglect of their six (6) child-
renl Inga Anne Carolyn Cowden, DOBI I.larch I~, 196), Lawrence Mark Cowden,
DOBI July I), 1964, Jacquelyn Lee Cowden, DOBI August 18, 1965, Michael
John Cowden, DOBI November 6, 1966, j'atrick James Cowden, DOBI November
20, 1967, Tanya Jean Cowden, nOBI March )1, 1970, for all their growing
up years - and his wife, undermining therpsychological and physical and
socio-economic welfare, rendering their condition intolerable and their
- II -
life burdensome, disadvantaged, deprived, the children's childhood cut
short, all displaced by indigence and resulting social stigma into utter
poverty, faced with the devastating threat of the children being re-
moved by ~uthoriti~s - caused by t~e now appearing Plaintiff's willful,
self-serv~ng, crim~nal conduct - w~thout remorse nor conscience all the
while, Furthermore, with several desertions - actual abandonment of his
wife and six then still minor children, of which the last took place
upon Thanltsgiving, November 1979, because his wife made it to be the
last one, finally, tired of the repeating upheavals.
In addition, despite the fact, that court orders for support of his
wife and children, for non-support, have existed against Lawrence W.
Cowden since March 29, 1978 inl
Franklin County Court, 39th Judieial District of Pennsylvania,
1170 1978 NS
#FR-I979-582-S/30546C
and under the Uniform Reciprocal Enforcement Act in the jurisdictions
ofl
Rockville, Maryland and Comanche County, Lawton, Oklahoma, where Lawrence
W. Cowden evaded authorities before he could be served notice.
Oklahoma County, Oklahoma, #FD-85-6891/TN 032417A
Lancaster County, Pennsylvania, #872569
York County, Pennsylvania, #38795, the latter, which now - since June
5, 1996, is attaching his wages, yet only for repayment to the Penn-
sylvania Department of Public ~elfare, for the inadequate Aid-to-Families-
with-Dependent-Children, received by his wife and children, having had
no other resources to defray their existence. The Plaintiff herein, has
willfully and criminally been in contemt of the courts and their orders
the maJority of years that the children were entitled to support from
him. H~s wife also never received any support for herself. Lawrence W.
Cowden's famous way of evadin~ court support orders, to keep from being
found by enforcement authorit~es anywhere, as well as to keep from being
found out by his wife in his adulterous relationships, was by going into
hiding in and out of state. His wife was always put into the situation
by the Domestic Relations Offices, to have to provide them with a cur-
rent address, again and again, on Lawrence W. Cowden's ever Changing
Whereabouts/addresses, or they would not act onmr non-support petitions
against him.
Of his many adulteries, that the Plaintiff herein engaged in, I, the
Defendant named herein, can name and provide information on at least
these bad credits to womanhood, having encountered them by discovery of
his adultery with each of them, in person I
Dorothy Hejlik, DOBI Oct. 10, 1951, last knolvn to reside atl
1403 West 85th st., Cleveland, Ohio 44102, can be contacted at her now
deceased mother's, Mildred Hejlik, who knew of all of it, addreSS/home,
now belonging to Dorothy Hejlik's sister and through herl
Ms. Karin Hejlik, 4046 Parkside dr., Cleveland, Ohio 44144, Phone I (216)
351-3367
The herein named Plaintiff, Lawrence ',1. Cowden, became eMployed n t the
VA- Hospital in TJrec!:,willc, Ohio 1:!,l!:l, nenr Cl"v,~lnn(l, on June 7, 1971.
~itl1in d~,ys tllC'n f'ncJ there, he met 'In.; lJc'3~n nn ndulterous relationship
with Dorothy Hejlik, who a1:.:;o ','lorlwd there, !lis lcp.;al wife - now named
the Defendant herein, hod n lot of ~usl1icions r~ile it WDS going on in
secret behind her bncJ(, but 1,,,( no ",,:n:; nn'! n.o way, t~ get and gatrer
evidence to exno,~c tlw~,. a ::l-: "tr~ni:er to :;':,1 ')f tlt,t ares find llmitcd
by the responsibility to enn' for the parties !;ix, small children" Il~ ,
alwnys tool: the one car, I"orced into poverty by 111m, in a rough 1 rOJect
- III -
/lousing nei~hborhood, Blacks pi tted a~ainst ',/hi ten she had nowhere to
turn about ~t, made to endure his ind~gnities, Whe~ she confronted him
about his quite obvious lies, as he tangled himself in his own he denied
everything, cleverly made up more lies and accused her of "just wanting
to fight" and continued his charade until eventually he _ they were found
out.
Conse9uent to his adultry with Ms. Hejlik, he was absent from work an
exess~ve amount of hours first, then days, during late June also July
August and September of 1971 and Ivas therefore terminated, : The here~~
named Plaintiff, Lawrence W. Cowden, by May 12, 1971, had been termin-
ated by the U.S.Army by General Discharge, for larceny and his involve-
ment in forgery of his military records, as also a habitual record of
petty thefts, insubordination, conduct unbecoming a soldier, going be-
fore, against the U.S.Army, while in the Service. - By sometime in June
1971, Lawrence '.'1. Cowden fathered and Ks. Dorothy Hejlik conceived in
adultery a child, a boy, born on January 19, 1972, in the Cleveland Gen-
eral Hospital, whom Lawrence \1. Cowden later and at baptism named after
his adoptive father, Allan Raymond(Cowden), for whom he had ever only
expressed hatred.
Upon receiving confirmation of Ks. Hejlik's pregnancy, Lawrence W.Cowden
rushed to have a Vasectomy done on September 27, 1971, in the Clinics of
University Hospitals in Cleveland, Ohio, Phone#(2I6)79I-7JOO, in an ef-
fort to cover up and deny his paternity at first, for which he needed his
wife's consent and he declared to her, that "he was doing it for her". _
While on his second military tour with his legal family in Germany 1969-
1971, U,S. Army doctors had already recommended to Lawrence W. Cowden,
to have a Vasectomy as the simplest birth-control for him and his wife,
since her health 'Nas becoming strained and he 'could' not keep nor make
raru{ due to his own habitual irresponsibility and conduct, which kept
him at low pay. His wife, the Defendant named herein, had to submit her-
self to undergo an abortion on April 2, 1971, by Dr. H. Peter Tarnesby
in London, England, referred to him by U.S. Army doctors, paid for by
the Army Emergency Relief Fund, to which Lawrence W. Cowden only too
eagerly gave his legal consent. _
Right about the date the child of Dorothy /lejlik and Lawrence -,./. Cowden
was born ( Jan. 19, 1972) in the Cleveland General Hospital, Cleveland,
O/l, his first son with his legal wife, Lawrence Mark Cowden, then 8 years
old, came dOlvn with a mysterious illness, the whole one side of his face
swelled up. Initially, the child's mother had taken him to the closest -
same hospital. The doctors could not find a cause for the symtoms and
kept him in the hospital for observation II days, released him when the
condition had cleared up; it was never explained, This was too much co-
incidence and gave cause to the suspicion, that Lawrence W. Cowden, the
criminal and con-artistic mind he had then already, had himself likely
done or given something to his legitimate son, to have him at same hospit-
al, to excuse his daily visits with his girlfriend and their illegitimate
son there. He insisted, that his wife notgo and left her homebound with
their other children, as practically always.
The whole truth of Lawrence ',I. Cowden's sordid, adulterous affair was
shed, after his wife's oldest daughter, Inga, left to spend the Summer
with her grandmother (who paid for it) in Berlin, Germany on June 18,1972.
On June 19, 1972 hebecame l'\udacious toward his wife, relentlessly demand-
ing, that she go' too. To convince him, that he could not make her leave
and certainly not without their other five children, against her will,
she told him to come with her to the downtown Cleveland, Ohio, IN8-Serv-
ices to have cbrification on the matter, They told him the same ir,front
of her. Nevertheless, he contimwd to argue with her as they left there,
Then in the lobby of that Pederal BuildinG, he Sei~ed a moment in the
- IV -
big crowd, turned and loft the building through other doors, hurried to
their ear and left without her, leaving his wife stranded in downtown.
She waited for him to return for a long time, but unfamiliar with the
areas she had to pass through for miles, she walked home, to be there be-
fore dark. 1n the preceding turmoil with Lawrence W. Cowden, she had
left her pocketbook at home and had not even busfare. She finally arrived
at home, only to find, that he had talcen their five younger children and
was gone, the house locked. She did not even have a Icey. Their landlord
and neighbor, who had watched the children, told her that he had been
there to piclc up the children and some luggage, that a woman resembling
her waited in the car, whom they thought to be his wife, but instead it
was Dorothy Ilejlik with their infant. Together with her and the children,
Lawrence W. Cowden had then willful deserted/abandoned his wife, abduct-
ed/kidnapped their five younger Children, the youngest age 2 years then,
from her and gone off to no one lenew where. Until, nearly two months
later, when he had a bill he had incurred at their hideout, sent to an
old address, which then was fon1arded to his wife, who incidently was
evicted, because Lawrence W. Cowden had not paid the rent for several
months. The pieces started falling into place and with some help of oth-
ers, his wife was able to locate his girlfriend's mother, Mrs. reildred
Hejlik, who was shocked just the same at all the lies and false pretences
then unraveling. She too, helped his wife in the'pursuit of them, to
find her children. Unfortunately, this kind lady has since deceased, but
her younger daughter, Karin Hejlik, at the same address, knows of it
and can verify what took place.
Lawrence W, Cowden and Dorothy Hejlik had run off all the way to James-
to\VIl, North Dakota, hiding out with the children and pretending to be
husband lO.nd wife, "r,ir. and r,lrs. CowGen an': their six children"in motels,
churches, to organizations and businesses, while keeping the children
under most primitive and deprived livinG conditions and poor care; had
traumatized the children ','rith th::t ano.1 telling them, that "their mother
no lonGer wanted them, so she ,'nd Inga had Gono bacJ: to Germany", in
their psyeholo.:;ical \iellbeino;, - Ei:J wife, in touch with various Ohio
agencies for help in loeatine; c.nd returning her children, on August Il,
I9?2, ventured on f' Ion,: bustrip out to Jamcsto';m, ND, to get them, Once
there, she sought the help of the police department, who already lenew
of ther.!. Police Captainiolff then, Phone/I (?OI )252-21114, after hearing
of the whole ordeal, by separate cruiser, had the real Jeirs. Cowden's
children pickcd up rnd reunited ':lith her.' 3y separate cruisers, he also
h::\d the illicit couple brought in. Facing the ridicule and i.11ninent char-
ges e):rrcsscd by Capt, "olfr to him, La\'irenCe \'/, Cowden was full of re-
Grets and begged his wife for forc;iv;eness. He was given 12 hours to got
out of the 3tate of ':orth "nl(Ota. Hi::; wife took hir:l back, but only under
his !Tor.!ise, that he would not '.;0 that aGain, which ::Jhe lived to regret
n::my tir.1o~; over :;incc then. ;'(eturning to Cleveland, Ohio, out of compass-
ion for her innocent ehild, his wife even tool:: his girlfriend, K5. lie jlik,
alon.:; bac](, only to h~,ve the lone; trip agitated by her, even with threats
of her Goinc; off and leavin:; the child bohind, her attcmpt::J to convinco
him to GO off with her aGain. Two of the children overhenro.1 their conver-
:;ations and told their nother. 3hc Gave hir.l an ultir:mtum and he declared
:lb rclation:3hip ';Iith [.'s, Hejlik as over.
Dorothy Hejli1-: hp.G. ~-:no'''!n c~l:L 8J~r:1 : i.h-.t 1 [I':..rcncc ,,'. Cowden was married
and was willing to go alone with hir: at r;ettin[; his 10[,;nl wife ::Jomehovl
out of the way, or to run off with him somewhere into hiding as thEYdid,
- Lawrence ~. Cowden's illegitimate child - in adultery with Dorothy
Hejlilc, Allan Raymond lIoj1ilc, sadly died in June of 1981, at age 9 years
in Cleveland, Ohio, as result of injurie::J he sustained at age 5 year::J,
- v -
when he was hit by a car.
In 1974, Lawrence \.1. Cowden too]c a job with the Marion Correctional
S~ate Institution, so the family moved to Marion, Ohio. Nothing too ob-
V10US happened, except some instances of anonymous mail received, ad-
dressed to him, on postcards, the contents suggesting connotations, He
would often have to go on trips, but they may not have always been busi-
ness trips required by his job, His wife came upon him one time as he
opened his wallet and could not miss a small packet with white powder.
Confronting him, he told her smartly, to mind her own business. She did
not want to go to the police, without proof at hand, afraid it would be
dealt with as just a domestic problem, as had happened some years earlier,
when he had hit his wife. By April 1976, Lawrence 11. Cowden was fired.
The family was evicted from the house that had come with the job. He
made no earnest effort to relocate the family, instead, deserted/aban-
doned the family, hiding out in Virginia, but did come back weeks later.
The second women, Lawrence ;1. Cowden's wife uncovered him in adultery
with, was an Annabelle Ilarnish of Rt. I, 10740 Claylick Rd" r.1ercers-
burg"Pennsylvania 17236; she is deceased since October 16, 1978, she
and the driver of the car she was in were drunk and crashed off the side
of a mountain in the Tuscarora Mountains. - In September 1976, Lawrence
\1, Cowden had moved his wife and children to wercersburg, PA 17236. He
had become shiftless once again, but spent lots of time absent from the
family and never ran out of excuses. On and off the family was on Pub-
lic Assistance. They had to move because of his irresponsibility. They
moved within Franklin County, Pennsylvania, to Saint Thomas. He had lied
to the landlord, that he "only has four children", which his wife was
confronted about some months later after Lawrence \'/. Cowden had become
delinquent with the rent. That was by Christmas of 1977, he was already
having an adulterous affair with Annabelle Ilarnish and aeserted his
family then to be with her, returned a week later with only lies. Then
on January 5, 1978, he deserted his family again and lived with Annabelle
Harnish, His wife soon thereafter found them out at her residence. By
(,jarch 1978, his wife filed the first non-support petition in the Franklin
County, PA Court, who then issued the first order Karch 29, 1978, In
April 1978, lie returned, apparantly with no better intentions than to
stifle the order. Annabelle lIarnish had found herself another beau mean-
time, but coincidently on the same day of her fatal car wreck, October
16, 1978, Lawrence il. Co~den deserted/abandoned his family again. - Al-
though Public Assistance had issued all AFDC-checlw to his name, he con-
trolled the money all before, but he not only had not paid rent, but also
not utili ties. Consequently, they were shut off, Ilis wife and children
had only oil-lamps for lighting, no running water, had to haul drinking-
water from a distant spring, \'lash launh:y by hand in a creek, log pond
\'10. tel' up a hill, to have flush-water for the toilet, coole and heat ba th-
\'later over a whole in the ~round outoide, built up with stoneo, replaced
to settler times. 1li3 wife certainly hno earned and deserves the "Pioneer
award", By November 1978, Lawrence ';;, CO\'Illen was suddenlybacle and wanted
the family to move dO\m to Gaithersburg, (,:arylnnd, with him, where, so
he claimed, he had a good job, was going to make good onthemfor all hio
wrongs, etc" etc."the usual line. ilL-; wife was not ready to go along
so quick and as a compromise offered to visit him with the children on
certain weekends, provided he ray for tlwir trip nnd I:eep, so they did,
He made no effort though to Get ap!Jroprinte hou~;ing for the family; wr'~;
himself only shnring an ap:->.rtement ',','ith :~omeone i.n ;"ontgomery VillnGe,
who worlced with him there in costruction, 'l'he dtuation was nothinG h'11f'
and nothinG whole,
Ili:-: fanily ::mrvived nnot~lcr wir.ter on their own in ,;t, 'I'hor:n~l, 1';\, By
:,prinG 1979, hi:-: wife h2rl found nnothcr hou:-:e ,-,t 7778 Buchanan 'l'rnil ,:e:Jt,
- VI -
r,lercersburg, 1'A 17236, and moved there with the children on April I,
1979. Un July IS, 1979, Lawrence ';1. Cowden'o wifc allowed him one more
chance, by letting him return to them, but it was 'not long and he had
fallen into his old trend again, In October 1979, he was fired because
of theft from aoompany in-house vending machine, from Nitterhouse Con-
crete Products, Chambersburg, PA. So the family was bac]t on \'Ielfare.
By Thanksgiving, November 1979, he deserted/abandoned his family again,
which his wife then finally decided to make the last time.
lie got a job with Nichols Dept. Store in Chambersburg, PA, shortly after
and it was there, that he met his co-worker, lonely widow, Helen T, Buba]t,
then residing at 302 Philadelphia Ave., Chambersburg, PA 172011 the
property belonging to Corpus Christi Catholic Church, next to it, Phone
#264-6317, of which she is a parishioner, She has moved since, but the
church knows her where-abouts. Lawrence iI. Cowdcn was living with her in
adultery, until he had relieved her of some large Dollar amounts, which,
incidently, he did not spent on his wife and children , nor pay in sup-
port for them, nor on his arrearages, Although she too, knew that he was
married, went right along with him,' "because as a widOl'/ she needed some
loving", she told his wife, when confronted by her. She called his wife
on her own, when eventually he had 'dumped' her,
By OctOber/November 1980 I L::1':lronec \'1. Cowden had a new girlfriend to live
with or live off: Janet Henry; her last known address was then at:
489 South 2nd St" Chambersburg, PA 17201, His wife and children saw him
there and his car parked there quite regularly, that was, until he swit~
to a new girlfriend.
By December 1980, his vlife uncovered him to be living in adultery with a
"Dee" Dolores E. Miller, at that time living at 1089 Lehman Rd., Cham-
bersburg, PA 17201. Her thell minor daughter Rosemary lived with them.
In early 1981 sometime, another daughter of hers ~oved in with them,
Carrie George, 2~ years old thon, She brought with her a little daughter,
DOlma, born in I979(her father is a David Gilbert of Newport, Perry Coun-
ty, PA), Carrie George was VCr'J preQ1ant \'lith a second child, which was
then born in June of 1~8I. They <,n moved to 1936 Lot I~ Philadelphia Ave,
end then to 2001} Lot 19 J'hilndC'lnhia Ave., Chambersburg, PA 17201.
:;oloros Miller's l:"st ::no','fl1 r.d,lreGs ',:res: 1;660 Lot72 Sycamore Grovc Rd.,
Chambersburg, PA 17201. - Duril1G JJa':lrence W, COI'!den' s ongoinG C'.dul terous
::lff2ir 'oIi tll Dolores :,:iller, at Gone point, he also started an adulterous
relf.'.tionship simultrrl1eou::>ly "Iith her dauGhter, Carrie GeorGe, On Eareh
J3, 1982, he and Carrie GeorGe disappeared together into hiding, first
in !'iGsouri, then on into Oklahoma, They hid in Lawton, Oklahoma (where
he had been stationed once in 1969 with his legitimate family at Fort
Sill), where they had thoroughly fooled a man and his church into helping
thcm, an Arthur A. Farrington III of Rugged Cross Ranch, Box 531, Elgin,
Comanche County, Oklahoma 73538, llis wife managed to make contact with
tha t man, In June of 1982, Lawrence \~. Cowden and Carrie George applied
for and received emergency food stamps at and from the Comanche County,
Oklahoma Public Assistance Office fraudulently as "I,ll'. and Mrs. Cowden".
By July 1982 he lived with Carrie George and her children until sometime
March 1983 at the Don Air Apartements, 3631 S. Robinson - Apt. 16, Okla-
homa City, OK 73109, which was also confirmed by the management office
Phonell (405 )632-7807. His wife does not know when exactly the two returned
to Pennoylvania, but was able to establish in 1988, veryfied by a neigh-
bor of theirs, that the two were then living at Laurelwood Trailer Court,
2580 LotI3 Lewisberry Hd., York !laven, I'A 17370, Once all her children
were considered emancipated and eut off from financial support from their
father, which they never receivi:!d anyway, ],awrence ';1, Cowden's wife no
loncer had to provide the Donestic Relations offices, as before, with his
ever chnn,o;inr; where-nbouts, finally able to have some :mni ty, so she
- VII -
thoue;ht. She lmew, that he,was somewhere living in yet another Trailer
Court in Cumberland County, along .3tate Houte II, PA. Yorlt County, PA-
Court sent her a copy of a wage attachment order against Lawrence \'I.
Cowden, dated June 5, 1996, which confirmed his current address, Whether
he lives there with Carrle George or any other cheap woman, does not
matter to her anymore. No self-respecting woman would want him anyway,
But, what matters to his wife is Justice, fairness and decency after
all her suffering, having given Lawrence ~, Cowden faithfully the best
years of her life only to have them and herself tread on by him, having
made her life miserable, often driving her to the edge.
Lawrence W. Cowden's wife and children had and have no one - no extended
Family in this country, who might have been a ltind of support system
throughout the troublesome years he had caused for them, His mother,
Doris Jean Cowden and sister, Nancy Lee Brannon, in 1964, had their
attorney issue and mail a statement to Lawrence William Cowden's pro-
spective wife then, the Defendant named herein, which directed, that
"both did/do not want any contact with their son/brother and that since
she was about to marry him, it would necessarily have to include her too",
Despite earlier attempts by his wife, once she had come here with him
from Germany, to bring harmony between them, his belligerent obsession
toward his mother throughout the years since, kept his wife and children
apart from and as perfect strangers with that grandmother, ,the in-laws,
to this day,
In his 10 (ten) point COl~plaint in Divorce, the herein named Plaintiff,
Lawrence ',lilliam Cowden sets forth untrue and incorrect facts in point
5. and point 7. Your Honorable Court needs to know, regarding point 5"
that the herein named Plaintiff and Defendant separated on November 23,
1979, not by mutual consent, nor by any court order, but by the Plaint-
iffb, Lawrence ,'I. Cowden's wanton desertion - actual abandonment of his
wife and six children, This was the last of several desertions, as des-
cribed heretofore. Hegarding point 7., there has indeed been a prior
action of divorce between the parties, taken by his wife, Annemarie H,
Cowden, as the Plaintiff, vs, Lawrence VI. Cowden, the Defendant then,
in 1980, in Franklin County Court, Pennsylvania, 39th Judicial District,
only at some point Lawrllnce'W. Cowden disappeared into hiding. Please
give your attention to the enclosed copies pertaining to that action.
Lawrence W. Cowden conveniently "forgot" these facts as all the many
others described afore.
Lawrence ';'. Cowden's wife has experienced much damage to her health over
the years and holds him responsible for her condition and situation. Al-
though she survived cancer since late 1994,thatordeal, without any help
from a comp~ionate spouse standing by her in support, has set her health
back even further, leaving her with disabilities today, that limit her
employability and earnings capacity. She is unemployed since October 18,
1996, unemployment benefits exhausted now since April 1997, has no means
of support to defray her costs of living and financial obligations coupled
with her most essential needs. Lawrence w. COWden, her legal husband, has
an obligation toward her, even presenting himself as the Plaintiff in
this action a~ainst his wife, Annemarie R. Cowden and she therefore begs
your Honorable Court to give her your fairest considerations available,
Respectfully submittedl
~
<:.1&'"
/~nemarle R. Cowen :.6__
5118 r,:anor Street
Lancaster, PA 17603
(717) 295-9206
June 19, 1997
, ,
v
,
; .
~
States of America,
7. The plaintiff has resided in the Commonwealth of Penn-
sylvania since September, 1976, until the present time, or for a
period of approximately four (4) years and seven (7) months
immediately previous to the commence~ent of this action and dur-
ing more than six (6) months immediately preceding the filing of
thin Complaint, she has been a bona fide resident of the Comreon-
wealth of Pennsylvania continuously and without interruption,
B. The defendant has resided in the Cocmonwealth of Penn-
sylvania since September, 1976, until the present time, or for a
period of appro:timately four (4) years and seven (7) months
immediately previous to the comm~nce~ent of this action and dur-
ins Dlore than six (6) months immediately preceding the filing of
this Complaint, he has been a bona fide resident of the Comrr,on-
wealth of Pennsylvania continuously and without interruption.
9. This action is not collusive.
10. No prior action of divorce or annulment of marriage
between the parties has been comrr:enced in this or any other juris-
diction.
11. Defendant in violation of his ~arriage vows and the
laws of this Commonwealth has offered such indignities to the per-
son of the plaintiff, she being the innocent and injured spouse,
as to render her condition intolerable and life burdensome.
WI{EREFOF~, plaintiff prays your Honorable Court in due ti~e
and according to law enter a decree divorcing her froo the bonds
of matrimony subsisting between her and the defendant, and she be
awarded the costs in this behalf e>:por.ced.
~
-~-
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~IY
1:,,1'''''' , I
CONPLAIUT IN DIVORCE UNDER SEC'IIm!
201(3)(1) OF THE DIVORCE CODE
12, TIle averments of paragraphs 1 through 11 set forth
above arc incorporateu herein ac though set forth at lenGth.
13, The defendant co~itted willful and malicious desertion
ar.d "as absent from the habitation of Annernarie R. Cowden, the
injured and innocent spouse, without a reasonable cause for the
period of one or more years.
l-mEREFOp.E, plaintiff prays your Honorable Court in due time
a~c according to law enter a decree divorcing her from the bonds
of matrimony subsisting between her and the defendant, anc she be
awardee the costs in this behalf expended,
COUNT III
CO~!PLAnIT IN DIVORCE UNDER SECTION
20l(c) OF THE DIVORCE CODE
14. The averments of paragraphs 1 through 11 and 13 set
fcrth above are incorporated herein as though set forth at length.
15. The ~~rriage is irretrievably broken.
l~lEP.EFORE, plaintiff prays your Honorable Court in due time
ar.~ according to law enter a decree divorcing her from the bonds
of matr~mony subsisting between her and the defendant, and she be
a"arded the costs in this behalf expended,
COUNT IV
COill'LAIUT IN DIVORCE UNDER SECTION
201(d)~THE DIVORCE CODE
16. The a'ferments of paragraphs 1 throuflh 11 and 13 and 15
-2.-
~.
nr.t for.th above arc incorporated herein as though set forth at
length.
~nIEPXFCFE, plaintiff prays your Honorable Court in due time
nnd according to low enter a decree eivorcing her free the bonds
of matrimony subsisting between her and the defendant, ane she be
nwarded the costs in this behalf expended.
COUNT V
ALINONY
17. The avercents of paragraphs 1 through 11 and 13 and 15
set forth above are incorporated herein as thcugh set forth at
length.
18. Plaintiff has ne income and assets to provide for her
needs.
19. Defendant is well able to prcvide fer plaintiff's needs,
but hos refused or otherwise failed to provide for the same on a
voluntary basis.
WHEREFORE, the plaintiff prays your Honorable Court to Qoke
on award of alimony in her favor.
COUNT VI
ALI110NY PENDENTE LITE, COUNSEL FEES AND
EXPENSES AND COSTS
20. The avernents of paragraphs 1 through 11 and 13, 15,
18 and 19 set forth above are incorporated herein as though set
forth at length,
21. Plaintiff is without adequate and sufficient funds to
support and maintain herself during the pendency of the litiga-
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IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT
OF PENNSYLVANIA - FRANKLIN COUNTY BRANCH
ANNEMARIE R. COWDEN,
Plaintiff
. CIVIL ACTION - LAW
vs.
F. R. 1979 - 582 - D
LAWRENCE W. COWDEN,
Defendant
In Divorce a v, m.
PETITION TO PROCEED WITHOUT PAYMENT OF COSTS
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
NOW COMES the petitioner Annemarie R. Cowden and respect-
fully represents that:
1. The petitioner is Annemarie R. Cowden, a sui juris
adult, who resides at 7778 Buchanan Trail West, Mercersburg,
Franklin County, Pennsylvania.
2. The respondent is Lawrence W. Cowden, a sui juris
adult, who resides at 1089 Lehman Road, Chambersburg, Franklin
County, Pennsylvania.
3. The petitioner has good and sufficient grounds for
divorce from the respondent on the grounds of adultery, deser-
tion, indignities and no fault.
4, The petitioner is unemployed. She receives public
assistance in the amount of $520.00 per month for herself and
the parties' six children. Petitioner also receives food
stamps in the amount of $270.00 per month and a medical assist-
ance card.
. " I
Mr
5. Your petitioner Annemarie R, Cowden has no income from
business, profession, dividends, interest, pensions, annuities,
social security, unemployment compensation, stocks, bonds, notes,
or any other source of income, other than indicated in Paragraph
4.
6. The petitioner has no checking account, but has a savings
account in which she has $85.00 to be used towards the rent pay-
ment due April 1, 1981.
7. The petitioner owns a 1972 Ford LTD station wagon which
was purchased in December, 1978, for $600.00. Said automobile
is presently worth approximately $200.00, but needs repairs to
its front end.
8. The petitioner owns no real estate.
9. The petitioner owns a minimal amount of household fur-
niture, some of which has been self-built.
10. The petitioner has the following average monthly ex-
penses for herself and her children:
Rent
Food
Electric
Phone
Fuel oil
Automobile insurance
Gasoline
Automobile repairs, inspec-
tions, registrations
Clothes
Total
$200.00
30.00 (in addition to food
stamps)
50,00
50.00
50.00
31.00
60.00
61.00
20.00
$552.00
11. The petitioner has no outstanding debts and obligations.
12. Petitioner has insufficient funds available for her
-2-
. " .
~1
living expenses, and the petitioner has refrained from spending
monies for needed items such as car repairs, clothes dryer repairs,
clothing for the children and social. activities for the children.
13. Your petitioner Annemarie R. Cowden is unable to pay
any of the costs of pursuing an action in divorce, including filing
fees, without creating a hardship for herself and without reducing
the amount allocated to the expenses itemized in Paragraph 10 and,
therefore, depriving herself and the parties' six children of the
basic necessities of life.
14. The respondent is currently subject to the payment of
a Support Order entered January 7, 1981, in which he was ordered
to pay for the support of his wife and six children the sum of
$200.00 bi-weekly. The petitioner receives none of this money
as it is paid to Public Assistance.
15. Your petitioner Annemarie R. Cowden will suffer immed-
iate and irreparable harm and injustice if denied the right to
pursue the above captioned divorce action in fo~ pauperis in
that, due to poverty, she will be financially unable to file the
complaint or otherwise pursue said action.
16. As stated in Paragraph 4 above, petitioner Annemarie R.
Cowden has been determined by the Commonwealth of Pennsylvania
Department of Public Welfare to be indigent and, therefore, eli-
gible for public assistance, food stamps, and medical assistance
for herself and her six children.
WHEREFORE, in accordance with Pennsylvania R.C.P. 1920.62,
petitioner Annemarie R. Cowden respectfully prays your Honorable
Court to relieve her from the payment of any costs in the divorce
action your petitioner is bringing against her husband Lawrence
:'
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IN TilE COUH'l' Ol~ C01.l~10N PLEA:'; 01"
CUr<iDl':Hl.AND COUNTY, PlmN:.iYLVANlA
LARRY COWDEN
I~ull name I
LAWRENCE WILLIAM COWDEN
Plaintiff
NO. 97-2895
vs.
CIVIL f,CTION LA~'I
ANNE-MARIE eO','WEN
Full"' name I
ANNEMARIE ROSEMARIE COWDEN
Defendant
IN DIVOHCE
ODJECTION TO COMPLAINT IN DIVOHC~
As the "Defendant" - named so in irony - in and by the Complaint in
Divorce, filed against me on May 30, 1997, by my legal husband,
Lawrence William COWden, he having the audacity after all, to present
himself as "fault free" and as the "Plaintiff" in this action, throu3h
his Attorney Jerry Drown, 3105 Old Gettysburg Rd., Camp Hill, FA 17011
- I am filing this definite objection, because there exist certain
significant unresolved issues between the two parties.
May it be knovm to your Honorable Court, that the Defendant named in
this action, does not have the means to hire an attorney, due to grave
socio-economic conditions brought onto her and her six (6) children by
the Plaintiff initially since 1971 already, not excluding prior inci-
dents even, by his actions and'or inactions, causing serious consequenc-
es for his wife - the Defendant named herein - and her children. There-
fore, the Defendant has no choice but to represent and defend herself.
Your Honorable Court needs to know, that the Plaintiff has in diShonesty
misrepresented and omitted certain facts in his 10 (ten) point Complaint
in Divorce, to make the two parties marriage appear as just simply
'irretrievably broken', not to have to accept his total guilt and fault
for that fact and to obtain now, 18 years later,after his last desertion
and abandonment of his family, a quick self-suiting divorce.
The marriage between the two parties began legally on Pebruary 18, 1965,
in Berlin-Zehlendorf, Germany - and became irretrievably broken by the
Plaintiff in this action, Lawrence W. Cowden, over the course of at least
- now 26 years, of the two parties' now 32 years legally existing mar-
riage, during which the Defendant in this action has been his ever faith-
ful yet injured wife, by viOlating his marriage vows and the laws of this
Commonweal th, prior also of the States of Ohio, North Da)tota, Oklahoma,
as of any civilized state, with such indignities to his wife, he now
claims as the "Defendant", aSI Among others, repeated and continued,
even multiple and deviant adulteries, wanton conniving, conartistic dis-
honesties, gross irresponsibility, gross neglect of their six (6) child-
renl Inga Anne Carolyn Cowden, DOBI March 4, 1963, Lawrence Mark Cowden,
DODI July 13, 1961} , Jacquelyn Lee Cowden, DOBI August 18, 1965, Michael
John COWden, DODI November 6, 1966, Patriclt James Cowden, DODI November
20, 1967, Tanya Jean Cowden, DODI March 31, 1970, for all their growing
up years - and his wife, undermining therpsychological and physical and
socio-economic welfare, rendering their condition intolerable and their
- II -
life burdensome, disadvantaged, deprived, the children's childhood cut
short, all displaced by indigence and resulting social stigma into utter
poverty, faced with the devastating threat of the children being re-
moved by authorities - caused by the now appearing Plaintiff's willful,
self-serving, criminal conduct - without remorse nor conscience all the
while. Furthermore, with several desertions - actual abandonment of his
wife and six then still minor children, of which the last took place
upon Than]tsgiving, November 1979, because his wife made it to be the
last one, finally, tired of the repeating upheavals.
In addition, despite the fact, that court orders for support of his
wife and children, for'non-support, have existed against Lawrence W.
Cowden since March 29, 1978 inl
Franklin County Court, J9th Judicial District of Pennsylvania,
1170 1978 N:.i
/11,'1{- I 97 9- 582 -S/JO 51}6C
and under the Uniform Reciprocal Enforcement Act in the jurisdictions
ofl
Rockville, Maryland and Comanche County, Lawton, Oklahoma, where Lawrence
W. Cowden evaded authorities before he could be served notice.
Oldahoma County, Oklahoma, IIFD-85-6891/TN 032417A .
Lancaster County, Pennsylvania, #872569
York County, Pennsylvania, #38795, the latter, which now - since June
5, 1996, is attaching his wages, yet only for repayment to the Penn-
sylvania Department of Public Welfare, for the inadequate Aid-to-Families-
with-Dependent-Children, received by his wife and children, having had
no other resources to defray their existence. The Plaintiff herein, has
willfUlly and criminally been in contemt of the courts and their orders
the ma~ority of years that the children were entitled to support from
him. H~s wife also never received any support for herself. Lawrence W.
Cowden's famous way of evading court support orders, to keep from being
found by enforcement authorities anywhere, as well as to keep from being
found out by his wife in his adulterous relationships, was by going 1nto
hiding in and out of state. His wife was always put into the situation
by the Domestic Relations Offices, to have to provide them with a cur-
rent address, again and again, on Lawrence W. Cowden's ever changing
Whereabouts/addresses, or they would not act onmr non-support petitions
against him.
Of his many adulteries, that the Plaintiff herein engaged in, 1, the
Defendant named herein, can name and provide information on at least
these bad credits to womanhood, having encountered them by discovery of
his adultery with each of them, in personl
Dorothy Hejlik, DOBI Oct. 10, 1951, last knolVl1 to reside atl
1403 West 85th St., Cleveland, Ohio 44102, can be contacted at her now
deceased mother's, Mildred Hejlik, who knew of all of it, addreSS/home,
now belonging to Dorothy Hejlik's sister and through herl
Ms. Karin He jlik, 4046 l'arkside dr., Cleveland, Uhio 44141f, Phone: (216)
351-3367
The herein named Plaintiff, Lawrence W. COWden, becama employeu at the
VA- Hospital in TIreclmvi.l1c, Ohio If4Ilfl, near Cleveland, on June 7, 1971.
Within days then and there, he met and bee;an an adulterous relationship
with Dorothy Hejlik, who also worltcd there. llis leGal wife - now named
the Defenuent herein, had a lot of suspicions while it I'/as Going on in
secret behind her back, but had no means and no way to get and gat~er
evidence to expose them, a yet strane;er to mueh,of that ar?a and llmlted
by the responsibility to care for the parties 3lX, :;ma~l ch~ldren,) H~
always toolt the one car. Forced into poverty by hlm, ~n a rough IroJect
- III -
Housing nei~hborhood, Blaclw pi tted a~ainst ~'Ihi ten she had nowhere to
turn ab~ut ~t, made.to endure his ind~nnities. Whe~ she confronted him
about h~s quite ObV10US lios, as he tangled himsolf in his own he denied
everythi~e;, cleverly made,up more lies and accused her of "juni wunting
to fight and continued IllS charade until eVlJntuully he _ they were found
out.
Conse9uent to his adultry with (,1s. Ilejlik, he was absent from work an
exess~ve amount of hours first, then days, durine late June also July
AUffUst and September of 1971 and Was therefore terminated. : The heroin
named Plaintiff, Lawrence W. Cowden, by May 12, 1971, had been termin-
ated by the U.S.^rmy by General Discharge, for larceny and his involve-
ment in fornery of his'military records, as also a habitual record of
petty thefts, insubordination, conduct unbecoming a soldier, going be-
fore, against the U.S.Army, while in the Service. - By sometime in June
1971, Lawrence W. Cowden fathered and Ms. Dorothy Hejlik conceived in
adultery a child, a boy, born on January 19, 1972, in the Cleveland Gen-
eral Hospital, whom Lawrence ~. Cowden later and at baptism named after
his adoptive father, Allan Raymond(Cowden), for whom he had ever only
expressed hatred.
Upon receiving confirmation of Ms. Ilejlik's pregnancy, Lawrence \'I.Cowden
rushed to have a Vasectomy done on September 27, 1971, in the Clinics of
University Hospitals in Cleveland, Ohio, Phonen(216)791-7300, in an ef-
fort to cover up and deny his paternity at first, for which he needed his
wife's consent and he declared to her, that "he was doing it for her". _
While on his second military tour with his legal family in Germany 1969-
1971, U.S. Army doctors had already recommended to Lawrence W. Cowden,
to have a Vasectomy as the simplest birth-control for him and his wife,
since her health was becoming strained and he 'could' not keep nor make
rarut due to his own habitual irresponsibility and conduct, which kept
him at low pay. His wife, the ,Defendant named herein, had to submit her-
self to undergo an abortion on April 2, 1971, by Dr. H. Peter Tarnesby
in London, England, referred to him by U.S. Army doctors, paid for by
the Army Emergency Relief Fund, to which Lawrence W. Cowden only too
eagerly gave his legal consent. _
Right about the date the child of Dorothy Ilejlik and Lawrence ',I. Cowden
was born ( Jan. 19, 1972) in the Cleveland General Hospital, Cleveland,
OH, his first son with his legal wife, Lawrence Mark Cowden, then 8 years
old, came down with a mysterious illness, the whole one side of his face
swelled up. Initially, the child's mother had taken him to the closest _
same hospital. The doctors could not find a cause for the symtoms and
kept him in the hospital for observation II days, released him when the
condition had cleared UPI it was never explained. This was too much co-
incidence and gave cause to the suspicion, that Lawrence It. COWden, the
criminal and con-artistic mind he had then already, had himself likely
done or given something to his legitimate son, to have him at same hospit-
al, to excuse his daily visits with his girlfriend and their illegitimate
son there. He insisted, that his wife notgo and left her homebound with
their other children, as practically always.
The whole truth of Lawrence W. Cowden's sordid, adulterous affair was
shed, after his wife's oldest dau~lter, Inga, left to spend the 3ummer
with her grandmother (who paid for it) in Berlin, Germany on June 10,1972.
On June 19, 1972~became audacious toward his wife, relentlessly demand-
ing, that she go' too. To convince him, that he could not malte her leave
and certainly not without their other five children, against her will,
she told him to come with her to the downtown Cleveland, Ohio, INJ-~erv-
ices to have clarification on the matter. They told him the same ir;1'ront
of her. Nevertheless, he continued to argue with her as they left there.
Then in the lobby of that Federal Building, he Se14cd a moment in the
- IV -
big crowd, turned and loft the buildinl1 throuah other doorn, hurried to
their car and left without her, leavinl1 hio wife stranuml in downtown.
She waited for him to return for a lone time, \Jut unfamiliar with the
areas she had to paOl; throul1h for miles, ohe wallte!] home, to be there be-
fore dark. 1n the preceding turmoil with Lawrence ',/. Cowden, ohe had
left her poclwtboolt at home and had not even bU::Jfare. :.ihe finally arrived
at home, only to find. that he had ta!ten their five younger children and
was gone, the house locked. Sho did not even have a !tey. Their landlord
and neiahbor, who had watched the children, told her that he had been
there to piclc up the children and ::Jome luggage, that II woman reoembling
her waited in the car, whom they thouaht to be hio wife, but inotead it
was Dorothy lIejlik with their infant. Together with her and the children,
Lawrence \'1. Cowden had then willful deserted/abandoned his wife, abduct-
ed/kidnapped their five younl1er children, the youngeot age 2 years then,
from her and gone off to no one Imew where. Until, nearly two months
later, when he had a bill he had incurred at their hideout, oent to an
old address, which then was fO~1arded to his wife, who incidently was
evicted, because Lawrence \'1. Cowden had not paid the rent for several
months. The pieceo started falling into place and with oome help of oth-
ers, hi::J wife wao able to locate his girlfriend's mother, r.irs. rdldred
Hejlik, who was shoelwd just the same at all the lieo and false pretences
then unraveling. She too, helped his wife in the'purouit of them, to
find her children. Unfortunately, this kind lady has since deceased, but
her younger daue;hter, Karin Hejlik, at the same addreo::J, lmows of it
and can verify what took place.
Lawrence W. Cowden and Dorothy Hejlik had run off all the way to Jameo-
town, North Da]tota, hiding out with the children and pretending to be
husband and wife, "r:'r. and r::re. Cowden an:1 their oix children"in moteln,
churches, to organizationc and bu:.:inecseo, while Iwepin~ the children
under most pritlitive and deprived living conditiono and \1001' care; had
traumatlr.ed the chil(~ren '..!i th tlwt and tellinG 't!Hm, tim t "lheir mother
no lonGer wanter; them, no :;he r'ncJ Ine;a had r;onc bc.c!: to.;i.!:'lilany", in
their peycholo.::;ical '..,cllbein:-;, - Hi:; wife, in touch with vnriouG Uhio
aaencien for help in locatinr, :"nd returning her children, on A\lIi,lnt Il,
1972, ventured on , lon'~ bustrip out to Jar,lC[;t.o~m. llD, to Get thcm, Once
there, she sought the help of the police department, '''Iho ::\lready Imew
of them. Police Cantain .;olff then , Phone/I (701) 25?-?/1I/;, after hearinG
of the whole ordeal, hy oepnrate cruioer, had the real iirG. Cowden'::
children picked up ~nd reunited with her. Dy neparate cruiocro, he aloo
had the illicit couple brought in. !;'e.cine the ridicule an'] i:l1r.1incnt char-
Gee e;':pre:mcd by capt, '.'!olff to him, Lawrence \,/, r.o\'luen was full of re-
Greto and begged hi:; wife for forgivenesfl. Ile wao ::;iven 12 hOllrc to get
out of the :.ltate of ,:orth Dalcota. Hin wife took him back, but only under
his promi:Je, thnt he would not do that aGain, which nhc lived to reGret
many times over :;inee then, Returning to Cleveland, Ohio, out of comr>aso-
ion for her innocent child, hi:.: wife even tool: hill Girlfriend, ["s. Ilejlilt,
alonG baclt, only to hr've the lone; trip ae;ita ted by her, even \'Iith threat:::
of her Goine; off and leavinG the child behind, her attempto to convince
him to GO off with her aGdn, Two of the children overlwnrd their convcr-
nations and told their Mother. ::;l1e l!ave him an ultimatum ':",nrl he declared
his relation::;hip with I:'s, lIejlik as over.
Dorothy lIejlil: hnd ]:nown all :'10;1"; tlwt I,:J,'..:rcnc0 ,:, GO'o'/den was married
and was willine; to go alone; with him at gettin/: hie lo:;nl wife :;omchoVl
out of the way, or to run off with him somewhere into hiding an they did.
- Lawrence W. Cowden's illegitimate child - in adultery with Dorothy
Hejli!t, Allan Haymond lIejli]t, sadly died in June of 19BI, at al!e 9 years
in Cleveland, Ohio, as renult of injuries he suntained at age 5 years,
- v -
when he was hit by a car.
In 1974, Lawrence ';1. Cowden too)t a job with tho [,larion Correctional
State Institution, so tho family moved to Marion, Ohio. Nothin~ too ob-
vious happencd, except some instances of anonymous mail received, ad-
dressed to him, on postcards, the contents suggesting connotations. lie
would often have to go on trips, but they may not have always been busi-
ness trips re'1uired by his job. lIis wife came upon him one time as he
opened his wallet and could not miss a small packet with white powder.
Confronting him, he told her smartly, to mind her own business. :';he did
not want to go to the police, without proof at hand, afraid it would be
dealt with as just a domestic problem, as had happened some years earlier.
when he had hit his wife. By April 1976, Lawrence W. Cowden Was fired.
The family was evicted from the house that had come with the job. He
made no earnest effort to relocate the family, instead, deserted/aban-
doned the family, hiding out in Virginia, but did come baclt weeks later.
The second women, Lawrence W. Cowden's wife uncovered him in adultery
with, Was an Annabelle Harnish of Rt. I, 10740 Claylick Hd., r,lercers-
burg,.Pennsylvania 17236, she is deceased since October 16, 1978, she
and the driver of the car she was in were drunlt and crashed off the side
of a mountain in the Tuscarora Mountains. - In September 1976, Lawrence
W. Cowden had moved his wife and children to ~ercersburg, PA 17236. He
had become shiftless onco again, but spent lots of time absent from the
family and never ran out of excuses. On and off the family was on Pub-
lic Assistance. They had to move because of his irresponsibility. They
moved within Franltlin County, Pennsylvania, to ::iaint Thomas. He had lied
to the landlord, that he "only has four children", which his wife Was
confronted about some months later after Lawrence \'1. CoY/den had become
delinquent with the rent. That was by Christmas of 1977; he was already
having an adulterous affair with Annabelle Harnish and deserted his
family then to be with her, returned a week later with only lies. Then
on January 5, 1978, he deserted his family again and lived with Annabelle
Harnish. His wife soon thereafter found them out at her residence. Dy
March 1978, his wife filed the first non-support petition in the Franldin
County, l'A Court, who then issued the first order I.larch 29, 1978. In
April 1978, He returned, apparantly with no better intentions than to
stifle the order. Annabelle Harnish had found herself another beau mean-
time, but coincidently on the same day of her fatal car wreck, Octobe:::-
16, 1978, Lawrence \'I. Cowden deserted/abandoned his family again. - Al-
though Public Assistance had issued all AFDc-checlm to his name, he con-
trolled the money all before, but he not only had not paid rent, but alse
not utilities. Consequently, they were shut off. His v/ife and children
had only oil-lamps for lighting, no running water, had to haul drinking-
water from a distant spring, wash laurrlIy by hand in a creek, log pond
water up a hill, to have flush-water for the toilet, coolt and heat bath-
water over a whole in the ground outside, built up with stones, replaced
to settler times. His wife certainly has earned and deserves the "Pioneer
award". Dy November 1978, Lawrence \'1. Cowden was suddenlybaclt and wanted
the family to move down to Gaithersburg, ~aryland, with him, where, so
he claimed, he had a good job, was going to make good on~anfor all his
wrongs, etc., etc."the usual line. His wife was not ready to go along
so quiclt and as a compromise offered to visit him with the children on
certain weeltcnds, provided he pay for their trip and keep, so they did.
He made no effort though to get appropriate housing for the family; 'was
himself only Sharing an apartement with someone in Montgomery Village,
who worked with him there in costruction. The situation waG nothing half
and nothing whole.
His family survived another winter. on their own in ::it, ThomaG, 1'11., By,
",''''';11tT .If'l""" 1~'" I.,i,,... '...' f"I("\'l~"'I(" ~l,n'I'l'''''l'' hnllt;('\ ~t """'..,r. Pllf"h:'"lnrln Tr:1]l ~'ln;tt.
- VI -
1.1ercersbura, l'A 172)6, and moved there with the chilcl1'en On April 1,
1979. Un July 15, 1979, Lawrence ';/. Cowden'::: wife allowed him one more
chance, by lettinr: him return to them, but it WM 'not lonG and he had
fallen into hio old trend aaain. In October 1979, he wa:J fired because
of theft from a oompany in-hou:::e vendinB machine, from Iii tterhouoo Con-
crete Productn, ChambernburG, l'A. So the fnmily Wan bncJ( on ;lelfare.
Dy Thanltsaiving, l/ovember 1979, he deserted/abandoned hia family aBain,
which his wife then finally decided to make the lnot timo.
He Bot a job with rlicholo Dept. :;tore in ChamberOburG, l'A, flhortly after
and it was there, that he met hio co-worker, lonely widow, Ilelen 'f. Dubalt,
then residine at )02 Philadelphia Ave., chambersburr;, PA 17201, the
l"roperty beloneinr; to Corpuo Chrioti Catholic Church, next to it, Phone
#264-6317, of which ohe is a pariohioner. ~he has moved since, but the
church Imowo her where-abouts. Lawrence W. Cowden wao livine with her in
adultery, until he had relieved her of oome laree Dollar amounto, which,
incidently, he did not spent on hio wife and children, nor pay in sup-
port for them, nor on his arrearaees. Although she too, knew that he was
married, went right alone with him,""because ao a widow ohe needed some
loving", she told his'wife, when confronted by her. 3he called his wife
on her own, when eventually he hall 'dumped' her,
Dy OctOber/November 1900, Ln\1ronce W.Cowden had a new girlfriend to live
with or live offl Janet Henry, her last known address was then atl .
489 South 2nd St., Chambersbure, PA 17201. His wife and children saw him
there and his car parlced there quite regularly, that was, until he swi t~
to a new girlfriend.
Dy December 1980, his wife uncovered him to be living in adultery with a
"Dee" Dolores E. Miller, at that time livine at I089 Lehman Rd., Cham-
bersburg, PA 17201. Her then minor daughter Rosemary lived with them.
In early 1981 oometime, another daughter of hers moved in with them,
Carrie George, 2~ ~'eara old thon, She brOUGht with hcr n liale ';auchter,
Lonna, born in 1979(her father is a David Gilbert of He~nort, Perry Coun-
ty, PA). Carrie GeorGe was very preQ1ant with a :;econc1 child, ':/hieh \'Iaa
then born in June of 1981. They aU moved to 1906 Lot Ij l'hiln,del phi::!. lIve.
~nd then to 2004 Lot 19 Philadelphia Ave., Chamber::;burc:;, 1'.', 17:~01.
Dolores Miller' 0 12,::;t l;nO\'/J1 adllre:;s \'!1lS I 11,660 l,ot72 ,jye2.l:tora Grove Ill!. ,
Chamberoburg, PA 17201. - DurinG J..o::lrcncc W. COI'/uen ,:; on:;oinc "lluHcrouo
affair Vii th Dolorca r,:illcr, at :::Or.1e point, he :),1:;0 ,;tnrtcd an allul teroua
relationahip aimul tnneoualy I'd th her dauGhter, Cal'l'ie GCOi",,,:C, On : 'r>,rch
I), 1982, he and Carrie George disappeared together into hi<Jinc;, firat
in roiissouri, then on into Oklahoma. They hid in Lawton, O)tlahoma (where
he had been stationed once in 1969 with his legitimate family at Port
Sill), where they had thoroughly fooled a man and his church into helping
them, an Arthur A. Farrington III of Rugged Cross Ranch, Dox 531, Elgin,
Comanche County, Oklahoma 73538. Ilis wife managed to malte contact with
that man. In June of 1982, Lawrence \1, Cowden and Carrie Georee applied
for and received emergency food stamps at and from the Comanche County,
Oklahoma Public Assistance Office fraudulently as "r'ir. and l,lrs. Cowden".
By July 1982 he lived with Carrie George and her children until sometime
March 1983 at the Bon Air Apartements, 3631 S. Robinson - Apt. 16, Okla-
homa City, OK 7)109, which was also confirmed by the manaBement office
Phone#(405)632-7807. His wife does not Imow when exactly the two returned
to Pennsylvania, but was able to establish in 1988, veryfied by a neigh-
bor of theirs, that the two were then living at Laurelwood Trailer Court,
2580 Lot13 Lewisberry Rd., Yorlt Haven, PA 17370. Once all her children
were considered emancipated and cut off from financial support from their
father, which they never received an~vay, Lawrence ~, Cowden's wife no
longer had to provide the Domestic Relations offices, as before, with hia
ever Changing where-abouts, finally able to have oome nanity, 30 3he
- VII -
thought. She knew, that he. wao oomewhere livinG in yet another 'frailer
Court in Cumberbnd County, alonG :Jtato Route II, PA. Yor]t County, l'A-
Court sent her a copy of a waGe attachment order ac;ainrJt I,awrence W.
Cowden, dated June 5, 1996, which confirmed hio current addreos, Whether
he liveo there with Carl'~e GeorGe or any other Cheap woman, doeo not
matter to her anymore. No self-respecting woman would want him anyway.
Dut, what mattero to hio wife is Justice, fairneoo and decency after
all her SUffering, having ~iven Lawrence ~. Cowden faithfully the best
years of her life only to have them and herself tread on by him, having
made her life mioerable, often driving her to the edge,
Lawrence W. Cowden's wife and children had and have no one - no extended
Family in thio country, who might have been a Idnd of support system
throughout the troublesome years he had caused for them, His mother,
Doris Jean Cowden and ointer, Nancy Lee Drannon, in 19611, had their
attorney issue and mail a statement to Lawrence ~illiam Cowden'o pro-
spective wife then, the Defendant named herein, which directed, that
"both did/dO not want any contact with their oon/brother and that since
she was about to marry him, it would necessarily have to include her too".
Despite earlier attempts by his wife, once she had come here with him
from Germany, to bring harmony between them, his belligerent obsession
tovlIlrd his mother throughout the years oince, kept his wife and children
apart from and as perfect strangero with that grandmother"the in-la~o,
to this day.
In his 10 (ten) point Complaint in Divorce, the herein named l'lalntiff,
Lawrence ~/illiam Cowden sets forth untrue and incorrect facts in point
5. and point 7. Your Honorable Court needs to know, regardine; point 5.,
that the herein named Plaintiff and Defendant separated on November 23,
1979, not by mutual consent, nor by any court order, but by the Plaint-
iffs, Lawrence if. Cowden's wanton deoertion - actual abandonment of his
wife and six ci',ildren, This wao the laot of oeveral desertions, ::lI.) des-
cribed heretofore. Regarding point 7., there has indeed been a prior
action of divorce between the partieo, taltcn by his wife, Annemarie ll.
Cowden, as the Plaintiff, vo. Lawrence ,'I. COWden, the Defendant then,
in 1980, in Franltlin County Court, Pennoylvania, 39th Judicial District,
only at some point llawrllnoEl::W. Cowden disappeared into hiding. Pleaoe
give your attention to the enclooed copies pertaining to that action.
Lawrence W. Cowden conveniently "forGot" these facts no all the many
others deocribed afore.
Lawrence \'/, Cowden's wife has experienced much damage to her health over
the years and holdo him responsible for her condition and situation. Al-
though she survived cancer since late 1994,thatordeal, without any help
from a compa$ionate spouse standing by her in support, hao set her health
back even further, leaving her with disabilities tOday, that limit her
employability and earningo capacity. She is unemployed since October 18,
1996, unemployment benefits exhausted now since April 1997, has no means
of support to defray her costo of living and financial obligations couple'
with her most eooential needs. Lawrence IV. Cowden, her legal hunband, ha,
an Obligation toward her, even presentinG himself ao the Plaintiff in
this action against his wife, Annemarie R. Cowden and ohe therefore bec;s
your Honorable Court to"give her your fairest considerations available,
Hespectfully submittcul
~,,,c&~,~~~~
,---Ar1nemarlClf:-towlYcn 'J/__
548 [,:anor ;jtrcct
Laneaotcr, 1'/\ 17GOJ
(717) 295-97.0(,
June 19, 1997
IN 'l'IIE COUll'!' Ol~ COW.l0N PLEA:; Of
CUr.:B,':IlLANIl COUN'!"{, 1'I';NIl:;YLVANlA
LAHHY CUlmEN
I"ull name I
LA~'IRENCE '..I]l.LIA~l CO:IDl;N
l'lain ~iff
vs.
NO. 97-2895
CIVIL hCTIUN l.^~
ANNE-MARIE Cl)',iULN
fo'ull' name I
ANNEMARm IW.iEMAIlIE COWDEN
~)l' fcndnnt
IN UIVOBCE
on,) Ec'rION TO C01.Il'LAINT IN DIVOHc::.
As the "Defendant" - named so in irony - in rind by the Complaint in
Divorce, filed against me on May )0, 1997, by my legal huaband,
Lawrence William Cowden, he having the audacity after all, to present
himself a:3 "fault free" and as the "Plaintiff" in this action. through
his Attorney Jerry Drown, 3105 Old Gettysburg Hd., Camp Hill, 1~ 17011
- I am filing this definite objection, because there exist curtain
significant unresolved issues between the two parties.
(,jay it be known to your Honorable Court, that the Defendant named in
this action, does not have the means to hire an attorney, due to grave
socio-economic conditions brought onto her and her six (6) children by
the Plaintiff initiall~ since 1971 already, not excluding prior inci-
dents even, by his act~ons and 'or inactions, causing serious consequenc-
es for his wife - the Defendant named herein - and her children. There-
fore, the Defendant has no choice but to represent and defend herself.
Your llonorable Court needs to know, that the Plaintiff has in diShonesty
misrepresented and omitted certain facts in his 10 (ten) point Complaint
in Divorce, to make the two parties marriage appear as just simply
'irretrievably broken', not to have to accept his total guilt and fault
for that fact and to obtain now, 18 years later,after his last desertion
and abandonment of his family, n quiclt self-suiting divorce.
The marriage between the two parties began legally on Pebruary 18, 1965,
in Derlin-Zehlendorf, Germany - and became irretrievably broken by the
Plaintiff in this action, Lawrence \'I. COWden, over ~he course of at least
- now 26 years, of the two parties' now )2 years legally existing mar-
riage, during which the Defendant in this action has been his ever faith-
ful yet injured wife, by viOlating his marriage VOVIS and the laws of this
Commonwealth, prior also of the States of Ohio, North Dakota, Oklahoma,
as of any civilized state, with such indignities to his wife, he now
claims as the "Defendant", aSI Among others, repeated and continulJd,
even multiple and deviant adulteries, wanton conniving, conartistic dis-
honesties, gross irresponsibility, gross neglect of their six (6) child-
rem Inga Anne Carolyn Cowden, DOBI March 4, 196), Lawrence (,lark Cowden,
DODI July 13, 1964, Jacquelyn Lee Cowden, DOBI August l8, 19G5, lolichael
John Cowden, DODI November 6, 1966, Patriclt James Cowden, DOll I Hovember
20, 1967, Tanya Jean Cowden, DaD: March 31, 1970, for all their erowing
up years - and his wife, undermining therpsychological and physical and
socio-econornic welfare, rendering their condition intolerable and their
- II -
l~,fe burdensome, disadvantnged, deprived, the children's childhood cut
short, all displaced by indigence and resulting social sti~ma into utter
poverty, faced with the devastating threat of the children being re-
moved by ~uthori~ies - caused by t~e now appearing Plaintiff's willful,
self-serv~ng, cr~minal conduct - wlthout remorse nor conscience all the
while. Furthermore, with several desertions - actual abandonment of his
wife and six then still minor children, of which the last took place
upon Thanltsgiving, November 1979, because his wife made it to be the
last one, finally, tired of the repeating upheavals.
In addition, despite the fact, that court orders for support of his
wife and children, for'non-support, have existed against Lawrence W.
Cowden since March 29, 1978 inl
Franklin County Court, 39th Judicial District of l'ennoylvania,
1170 1978 N:.i
/Il~H-I 979- 582-S/3051~6C
and under the Uniform Reciprocal Enforcement Act in the jurisdictions
of:
Rockville, Maryland and Comanche County, Lawton, Oklahoma, where Lawrence
W. Cowden evaded authorities before he could be served notice.
Oklahoma County, Oklahoma, #FD-85-6891/TN 032417A .
Lancaster County, Pennsylvania, #872569
York County, Pennsylvania, #38795, the latter, which now - since June
5, 1996, is attaching his wages, yet only for repayment to the Penn-
sylvania Department of Public Welfare, for the inadequate Aid-to-Families-
with-Dependent-Children, received by his wife and children, having had
no other resources to defray their existence. The Plaintiff herein, has
willfully and criminally been in contemt of the courts and their orders
the majority of years that the children were entitled to support from
him. His wife also never received any support for herself. Lawrence W.
Cowden's famous way of evading court support orders, to keep from being
found by enforcement authorities anywhere, as well as to keep from being
found out by his wife in his adulterous relationships, was by going 1nto
hiding in and out of state. His wife was always put into the situation
by the Domestic Relations Offices, to have to provide them with a cur-
rent address, again and again, on Lawrence W. Cowden's ever Changing
Whereabouts/addresses, or they would not act onmr non-support petitions
against him.
Of his many adulteries, that the Plaintiff herein engaged in, I, the
Defendant named herein, can name and provide information on at least
these bad credits to womanhood, having encountered them by diocovery of
his adultery with each of them, in personl
Dorothy Hejlik, DOBI Oct. 10, 1951, last known to reside atl
1403 West 85th St., Cleveland, Ohio 44102, can be contacted at her now
deceased mother's, Mildred Hejlik, who knew of all of it, address/home,
now belonging to Dorothy Hejlik's sister and through herl
Ms. Karin Hejlik, 4046 Parkside dr., Cleveland, Ohio 44141~, Phone: (216)
351-3367
The herein named Plaintiff, Lawrence W. Cowden, became employed at the
VA- Hospital in Dreckr;ville, Ohio 1,41',1, near Cleveland, on June 7, 1971.
\11 thin days thcn and there, he met and bee;nn an adulterous relationship
with Dorothy Hejlik, who also Vlorlted there, Ilia legal wife - now named
the Defendent herein, had u lot of suspicions while it was Going on in
secret behind her baclt, but had no me~ns and no way to get and gat~cF
evidence to expose them, a yet stranger to.mlch,of that ar~a and llmlted
by the responsibility to cnre for the part~eo SlX, Gma~l ch~ldren., ll~
always tool: the one car. Forced into poverty by h~m, ln a rough j-roJect
- III -
Housin~ nei~hborhood, Dlacks pi tted a~ainst ','hi ten she had nowhere to
turn about ~t, made to endure his ind1enities, Whe~ she confronted him
about his quite obvious lies, as he tangled himself in his own he deniec
everything, cleverly made up more lies and accused her of "just wanting
to fight" and continued his charade until eventually he _ they were found
out.
Conseq.uent to his adultry with Ms. Hejlik, he was abnent from work an
exess~ve amount of hours first, then days, during late June also July
August and September of 1971 and was therefore t~rminated. : The here~n
named Plaintiff, Lawrence W. COWden, by May 12, 1971, had been termin-
ated by the U.S.Army by General DisCharge, for larceny and his involve-
ment in forgery of his' military records, as also a habitual record of
petty thefts, inSUbordination, conduct unbecoming a soldier, going be-
fore, against the U.S.Army, while in the Service. - Dy sometime in June
1971, Lawrence \'I. Cowden fathered and Ms. Dorothy Hejlik conceived in
adultery a child, a boy, born on January 19, 1972, in the Cleveland Gen-
eral Hospital, whom Lawrence W. Cowden later and at baptism named after
his adoptive father, Allan Raymond(Cowden), for whom he had ever only
expressed hatred.
Upon receiving confirmation of Ms. Hejlik's pregnancy, Lawrence \'I.Cowden
rushed to have a Vasectomy done on September 27, 1971, in the Clinics of
University Hospitals in Cleveland, Ohio, Phone#(216J79I-7JOO, in an ef-
fort to cover up and deny his paternity at first, for which he needed his
wife's consent and he declared to her, that "he was doine it for her". _
While on his second military tour with his legal family in Germany 1969-
1971, U.S. Army doctors had already recommended to Lawrence W. Cowden,
to have a Vasectomy as the simplest birth-control for him and his wife,
since her health was becoming strained and he 'could' not keep nor make
rarut due to his own habitual irresponsibility and conduct, which kept
him at low pay. His wife, the .Defendant named herein, had to submit her-
self to undergo an abortion on April 2, 1971, by Dr. H. Peter Tarnesby
in London, England, referred to him by U.S. Army doctors, paid for by
the Army Emergency Relief Fund, to which Lawrence W. Cowden only too
eagerly gave his legal consent. _
Right about the date the child of Dorothy lIejlik and Lawrence \'I. Cowden
was born ( Jan. 19, 1972) in the Cleveland General Hospital, Cleveland,
OH, his first son with his legal wife, Lawrence r.lark Cowden, then 8 years
old, came down with a mysterious illness, the whole one side of his face
swelled up. Initially, the child's mother had taken him to the closest _
same hospital. The doctors could not find a cause for the symtoms and
kept him in the hospital for observation II days, released him when the
condition had cleared UPI it was never explained. This was too much co-
incidence and gave cause to the suspicion, that Lawrence I"~. CoY/den, the
criminal and con-artistic mind he had then already, had himself likely
done or given something to his legitimate son, to have him at same hospit-
al, to excuse his daily visits with his girlfriend and their illegitimate
son there. He insisted, that his wife notgo and left her homebound with
their other children, as practically always.
The whole truth of Lawrence W. Cowden's sordid, adulterous affair was
shed, after his wife's oldest daughter, Inga, left to spend the 3ummer
with her grandmother (who paid for it) in Berlin, Germany on June IB,1972.
On June 19, 1972hebecame audacious toward his wife, relentlessly demand-
ing, that she go' too. To convince him, that he could not malw her leave
and certainly not without their other five children, against her will,
she told him to come with her to the downtown Cleveland, Ohio, INJ-:lerv-
ices to have clarification on the matter. They told him the samo infront
of her. Nevertheless, he continued to argue with her as they left there.
Then in the lobby of that Federal Building, he sei4cd a moment in the
- IV -
big crowd, turned and left the building through other doorn, hurried to
their car and left without her, leaving hi~ wife stranded in downtown.
She waited for him to return for a long time, but unfamiliar with the
areas she had to pas~ through for miles, she wallted home, to be there be-
fore dark. ln the preceding turmoil with Lawrence ';1. Cowden, ::;he had
left her poc)tetbook at home and had not even bu~fare. :.ihe finally arrived
at home, only to find, that he had talten their five younger children and
was gone, the house locked. She did not even have a Itey. 'rheir landlord
and neighbor, who had watched the children, told her that he had been
there to pick up the children and some luggage, that a woman resembling
her waited in the car, ,whom they thought to be hi~ wife, but instead it
was Dorothy llejlik with their infant. Together with her and the children,
Lawrence W. Cowden had then willful deserted/abandoned hi~ wife, abduct-
ed/kidnapped their five younger children, the youngest age 2 years then,
from her and gone off to no one knew where. Until, nearly two months
later, when he had a bill he had incurred at their hideout, sent to an
old address, which then was fo~~arded to his wife, who incidently was
evicted, because Lawrence W. Cowden had not paid the rent for several
months. The pieces started falling into place and with some help of oth-
ers, his wife was able to locate his girlfriend's mother, r,irs. rdldred
Hejlik, who was shoclced just the same at all the lies and false pretences
then unraveling. She too, helped his wife in the'pursuit of them, to
find her children. Unfortunately, this kind lady has since deceased, but
her younger daughter, Karin Hejlik, at the same addres~, Imows of it
and can verify what took place.
Lawrence W. Cowden and Dorothy Hejlik had run off all the way to James-
town, North Daltota, hiding out with the children and pretending to be
husband and wife, "r.jr. and l,irs. Cowden and their six children"in motelG,
churches, to oreanizations and bUGinesse~, \'lhile keepinG the children
under most prir,litive and deprived livinc; condition:] and poor carel had
traumatized the children ':!ith thl'.t amI tellinc; thot.1, that "their mother
no longer \'lD.ntccl them, GO ,she pnd Inga had Gonc hac!: to (:cr'many", in
their pGycholo.::;ieal \'lcllbdn.:;. - Hi;; wife, in tOllch \'lith varioui: Ohio
agencies for help in loea tine; :l.nd returning her childrcn, on Aug',IGt 11,
1972, ventured on r', Ion:: bustrip out to Jame::to':II1, liD, to Get them. Once
there, she sought the help of the police department, ':lho already knew
of them. Police Captain ','/olff thcn , Phone/I (701) 25?-?hl'j" after hcaring
of the whole ordeal, by separate cruiser, had the rcal j.irG. Cowden's
children piclccd up :>.nd reunited vlith hcr. By ~eparate crui:;crs, hc also
had the illicit couplc brOUGht in. Pacing the ridiculc and bmincnt ehar-
GeG exprc:::sed by Capt, "!olff to him, Lawrence 1'1. Cowden was full of ru-
c;rets and begged hiIJ wife for forgiveness. lle waG ;;ivcn 12 hour:; to get
out of the :.Jtate of i:orth Dalcota. HlG wife took him b~,clc, but only under
his promi::w, that he would not do that again, which :;hc lived to rec;ret
many times over ::;incc then, ReturninG to Cleveland, Ohio, out of eomrlaGs-
ion for her innocent child, his wife even tool: hi:; c;irlfricn(~, r,s. llejlik,
along bac)t, only to h:'.ve the lonG trip agitated by her, cvcn with threat:;
of her going off and leavinG the child behind, her attclnpt:; to convince
him to go off with her aGain. Two of the children ovcrhcnru their conver-
sations and told their mother. 8hc gave him an ultimatum ""nd he declared
hi::; relationship with r:'G, llejlilt as over.
Dorothy Ilejlilc had ImO\'lI1 all ::;lo:1'~ that Lawrencc ,!. GO\'idnn waG married
and was willing to go alone with him at r;ettint: hie legal wife somohOVl
out of the way, or to run off with him somewhere into hiding as th~did.
- Lawrence \'1. Cowden's illeei timate child - in adultery with Dorothy
Hejlilt, Allan Raymond lIejlik, sadly died in June of 1981, at aGe 9 years
in Cleveland, Ohio, as result of injuries he sustained at age 5 years,
- v -
when he was hit by a car.
In 1974, Lawrence ','/. Cowden toolt a job with the l,larion Correctional
State Institution, so the family moved to Marion, Ohio. 1I0thing too ob-
vious happened, except some instanccs or anonymous mail received, ad-
dressed to him, on postcards, the contents suggesting connotations. He
would oftcn have to go on trips, but they may not have always been busi-
ness trips re~uired by his job. His wife came upon him one time as he
opened his wallet and could not miss a small packet with white powder.
Confronting him, he told her smartly, to mind her own business. :.ihe did
not want to go to the police, without proof at hand, afraid it would be
dealt with as just a domeotic problem, as had happened some years earlier.
when he had hit his wire. Dy April 1976, Lawrence 11. Cowden Was fired.
The family was evicted from the house that had come with the job. lie
made no earnest effort to relocate the family, inotead, deserted/aban-
doned the family, hiding out in Virginia, but did come bnclt v/eelm later.
The second women, Lawrence W. Cowden's wife uncovered him in adultery
with, Was an Annabelle Harnish of Rt. I, 10740 Claylick Hd., r,lercers-
burg"Pennsylvania 172)6, she is deceased since October 16, 1978, she
and the driver of the car she was in were drunk and crashed off the side
of a mountain in the Tuscarora Mountains. - In :.ieptember 1976, Lawrepce
W. Cowden had moved his wife and children to Mercersburg, PA 17236. He
had become shiftless once again, but spent lots of time absent from the
family and never ran out of excuses. On and off the family was on Pub-
lic Assistance. They had to move because of his irresponsibility. They
moved within Franldin County, Pennsylvania, to :::iaint Thomas. He had lied
to the landlord, that he "only has four children", which his wife was
confronted about some months later after Lawrence ~. CoY/den had become
delinquent with the rent. That was by Christmas of 19771 he was already
having an adulterous affair with Annabelle Harnish and deserted his
family then to be with her, returned a week later with only lios. Then
on January 5, 1978, he deserted his family again and lived with Annabelle
Harnish. His wife soon thereafter found them out at her residence. By
March 1978, his wife filed the first non-support petition in the Frarutlin
County, PA Court, who then issued the first order March 29, 1978. In
April 1978, He returned, apparantly with no better intentions than to
stifle the order. Annabelle Harnish had found herself another beau mean-
time, but coincidently on the same day of her fatal car wreclt, October
16, 1978, Lawrence II. Cowden deserted/abandoned his family again. - Al-
though l~blic Assistance had issued all AFDc-checJts to his name, he con-
trolled the money all before, but he not only had not paid rent, but also
not utilities. Consequently, they were shut off. His wife and children
had only oil-lamps for lighting, no running water, had to haul drinking-
water from a distant spring, wash laurDIy by hand in a creelt, log pond
water up a hill, to have flush-water for the toilet, coolt and heat bath-
water over a whole in the ground outside, built up with stones, replaced
to settler times. His wife certainly has earned and deserves the "Pioneer
award". By November 1978, Lawrence W. Cowden was auddenlybaclt and wanted
the family to move down to Gaithersburg, Maryland, with him, where, so
he claimed, he had a good job, Was going to make good onthanfor all his
wrongs, etc., etc.,. the usual line. His wife was not ready to go along
so quic]t and aa a compromise offered to visit him with the children on
certain wee]tenda, provided he pay for their trip and keepI so they did.
He made no effort though to get appropriate housing for the family I was
himself only aharing an apartement with aomeone in r.lontgomery Village,
who worked with him there in costruction. The oituation was nothing half
and nothing whole.
His family survived another winter.on their own in ;>t. Thoman, I'A',Dy,
",~i"..,. .J'"'''''''' 1;.. ...i.("... 1...' "............' ...., .,Ih"1' l""I"" ~~. ,.,,,..,p. n'1"'h~n!'ln 'Prfl11 \'l~~t.t
- VI -
l,lercersbure, l'A 17236, and moved there with the children on April 1,
1979. Un July 15, 1979, Lawrence ';1. Cowden' G wife allowed him one moro
chance, by lettinr: him return to them, but it waG 'not lone and he had
fallen into hiG old trend aeain. In Octobor 1979, he wa:: fired because
of theft from a oompany in-houGe vendine machine, from Hi tterhouae Con-
crete Producta, Chambersburc;, 1'11. So the family wan baclt on ;'Ielfare.
Dy ThanltseivinG, 1I0vember 1979, he deserted/abandoned hia family again,
which his wife then finally decided to malte the bat time.
lie Bot a job with Nichol::; Dept. Store in Chambersbur[;, }lA, shortly after
and it was there, that he met his co-worker, lonely widow, Helen 'r. Dubak,
then residint:: at 302 Philadelphia Ave., Chambersbure, I'll 172011 the
~roperty beloneine to Corpus Christi Catholic Church, next to it, Phone
U264-6317, of which she is a parishioner. She has moved Gince, but the
church ImowG her where-abouts. Lawrence \'I. Cowden wall livine with her in
adultery, until he had relieved her of some large Dollar amounts, which,
incidently, he did not spent on his wife and children, nor pay in aup-
port for them, nor on his arrearat::es, Althouah she too, lmew that he was
married, went rieht alone with him,.'..because aa a widow she needed some
loving", she told his wife, when confronted by her. She called hia wife
on her own, when eventually he had 'dumped' her,
Dy OctOber/November 1900, LD.\'lrence 1'1. Cowden had a new eirlfriend to live
with or live off: Janet Henryl her last known addresG waa then atl .
489 South 2nd st., Chambersburg, PA 17201. His wife and children Gaw him
there and his car parlced there quite regularly, that was, until he swi tehed
to a new girlfriend.
By December 1980, his wife uncovered him to be livint:: in adultery with a
"Dee" Dolores E, Miller, at that time living at l089 Lehman Hd., Cham-
bersburg, PA 17201. Her then minor daughter Rosemary lived with them.
In early 1981 sometime, another daughter of hers moved in with them,
Carrie George, 2~ ~'eara old than. She broueht with her it little daUGhter,
Donna, born in 1979(her father i:; a David Gilbert of [lcwDort, Perry Coun-
ty, PA). Carrie GeorGe was very pre[;l1ant vtith a IJeeond child, \'Ihich waG
then born in June of 1981. They <\11 moved to 1906 Lot If 1'Ilibrlelphin Ave.
and then to 2004 Lot 19 I'hiladelphia Ave., Chamber:;burc;, 1'.'1 17~()1.
Dolores Miller's l~,Gt lmown adtlre:m I'm,s: 1,660 Lot7,' ,jyealUorc 'lrove P.tl.,
Chambersburg, PA 17;'~OI, - DurinG Lawrence 1'1. COI'!don':J onGoinG adulterouG
affair with DoloroG !,:iller, at nome point, he alno ~;tHrterl an auul terouG
relationnhip simul taneoualy with her daughter, Carl'ic GeorGe, tin I'arch
13, 1982, he and Carrie George di:;appeared tOBether into hiGin{;, l'irDt
in !oiissouri, then on into Oklahoma, They hid in Lawton, Oltlahoma (where
he had been stationed once in 1969 with hi:; legitimate family at l~ort
Sill), where they had thoroughly fooled a man and his church into helping
them, an Arthur A. FarrinGton III of Rugged Cross Hanch, Dox 531, Elgin,
Comanche County, Oldahoma 73538. His wife mana Bed to malte contact with
that man. In June of 1982, Lawrence \'I. Cowden and Carrie Georee applied
for and received emergency food stamps at and from the COlnanche County,
Oklahoma Public Assistance Office fraudulently as "!',]r. and [,Irs. Cowden".
By July 1982 he lived with Carrie George and her children until sometime
March 1983 at the Bon Air Apartements, 3631 S. Robinson - Apt. 16, Okla-
homa City, OK 73109, which was also confirmed by the manaeement office
Phone#(405)632-7807. !lis wife does not Imow when exactly the two returned
to Pennsylvania, but was able to establish in 1988, veryfied by a neigh-
bor of theirs, that the two were then living at Laurelwood Trailer Court,
2580 Lot13 Lewisberry Rd., Yorlt Haven, PA 17370. Once all her children
were considered emancipated and cut off from financial support from their
father, which they never received anyway, Lawrence ,;/, CO\'ltlen' s wife no
longer had to provide the Domestic Relations officea, as before, with his
ever changine where-abouts, finally able to have some nanity, so ahe
- VII -
thought. She knew, that he,wao somewhere livin~ in yct another Trailer
Court in Cumberlond County, alon~ Statc Route II, PA. Yor)t County, PA-
Court sent her a copy of a waGe attachment order a~ain:Jt Lawrence 'il.
Cowden, dated June 5, 1996, which confirmed hio current addruss. Whether
he lives there with Carr~e Geor~e or any other cheap woman, docs not
matter to her anymore. flo self-l'e(lpecting woman would want him anyway.
Dut, what matters to hio wife is JU(ltice, fairncso and decency after
all her suffering, having uiven Lawrence \'1. Cowden faithful1~' the best
yearo of her life only to have them and herself tread 011 by him, having
made her life miserable, often driving her to the edee.
Lawrence W. Cowden's wife and children had and have no onu - no extended
F'amily in this country, who might have been a Idnd of support syotem
throughout the troublesome years he had caused for them. His mother,
Doris Jean Cowden and sister, Nancy Lce Drannon, in 1961f, had their
attorney issue and mail a statement to Lawrence ~Iilliam Cowden's pro-
spective wife then, the Dofendant named herein, which directed, that
"both did/dO not want any contact with their son/brother and that since
she was about to marry him, it would necessarily have to include her too",
Despite earlier attempts by his wife, once she had come here with him
from Germany, to bring harmony between them, his bcllieerent oboession
toward his mother throughout the years since, Itept his wife and children
apart from and as perfect otrangers with that ~randmother, ,the in-la'vs,
to this day.
In his 10 (ten) point COJ:lplaint in Divorce, the herein named Plaintiff,
Lawrence William Cowden sets forth untrue and incorrect facts in point
5. and point 7. Your Honorable Court needs to !enow, reearding point 5"
that the herein named Plaintiff and Defendant separated on November 2),
1979, not by mutual consent, nor by any court order, but by the Plaint-
iffs, Lawrence ,;t. Cowden's wanton desertion - actual abandonment of his
wife and six children, This was the last of several dcsertionn, ao des-
cribed heretofore. Regarding point 7., there has indeed been a prior
action of divorce between the partieo, taltcn by his wifc, I\nnemarie H.
Cowden, as the Plaintiff, vs. Lawrence ~I. Cowden, . the Defendant then,
in 1980, in Pranklin County Court, Pennsylvania, 39th Judicial District,
only at some point Lawrllnce;:W. Cowden disappearcd into hiding. Please
give your attention to the enclosed copies pertaining to that action.
Lawrcnce W. Cowden conveniently "forgot" thenc facto as all the many
others described afore.
Lawrence ~. Cowden's wife has experienced much dama~e to her health over
the years and holdo him responsible for her condition and situation. Al-
though she survived cancer since late 1994,thatordeal, without any help
from a compa$ionate spouse standing by her in support, has set her health
back even further, lcaving her with disabilities today, that limit her
employability and earnings capacity. She is unemployed since October 18,
1996, unemployment benefits exhausted now since April 1997, has no means
of support to defray her cooto of living and financial obligations couple'
with her most essential needs. Lawrence IV. Cowden, her legal husband, has
an obligation toward her, even presenting himself as the Plaintiff in
this action against his wife, Annemarie R. Cowden and she therefore bees
your Honorable Court to"givc her your fairest considerations available.
Respectfully submitted I
/:2~~u;<-~
,-1innemane R, Cowden "'-
548 r,lanor :.itreet
Lancaster, ~\ 1760)
(717) 2')5-9206
June 19, 1997
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FAMILY LAW CLINIC
A .crvice 10 lhe communit)' by IludentJ
from 1110 Dickinson School ur LA\V
or The Pennsylvania Stale Unh.'cnil)'
'Ihe Ible r. Shughart Cunununily Law Cenler
4' Nonh I'in Slreet
l'arli.I" r.\ 170IJ,21l'J')
(717) 24).2%8
f..: (717) 243.3639
October 21, 1998
Honorable Edward E, Guido
Court of Common Pleas
Courthouse Square
Carlisle, Pa. 17013
F ;J.t
-
,.-
Re: Cowden v, Cowden, No, 97-2895 Civil Tenn
Lack of Notice of October 16 Hearing on Petition of
the Family Law Clinic to Withdraw as Counsel
Dear Judge Guido:
Because I have some personal knowledge about this maller, my colleague, Bob Rains,
has asked me to respond to your request that we try to detennine why this office was not aware
of the hearing in the referenced maller, scheduled for October 16th at 3:00 p,m, As Bob told
you, we did not learn of the hearing on our Petition to Withdraw until moments before it took
place,
I recall receiving (from Ms, Cowden) her Response to our Petition. along with her cover
leller, Those documents arrived in our office on OClober 5. 1998. On or about October 13th,
we received another copy of the Response from your Chambers, I distinctly remember that doc-
ument arriving in our office and the comment of our secretary that she knew that it had come
from your chambers only because the envelope bore your return address, There was nothing
in the envelope other than the copy of Ms, Cowden's Response, I am certain that the Order
selling the hearing was not enclosed,
In retrospect, perhaps we should have called your office ami made further inquiry, We
apologize for our role in this breakdown of communications,
~;~~
Donald Marritz
Staff Attorney
c: Prof. Robert E. Rains
PENNSrATE
., The Dickinson School of Law
An Equal Opponunity Uni\'~nil)'
LARRY COWDEN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
ANNE-MARIE COWDEN,
DEFENDANT
CIVIL ACTION - LAW
IN DIVORCE
97-2895 CIVIL TERM
ORDER OF COURT
AND NOW, this 30th day of October, 2001, in the case
of Cowden versus Cowden at No. 97-2895 Civil Term, and counsel for
the Plaintiff, Jerry Brown, Esquire, and Plaintiff himself having
appeared in court and requested that the case remain active for a
period of at least 6 months, and there being no opposition thereto
at this time, the case is stricken from the purge list upon the
condition that activity occur on the docket within 6 months. In
the absence of such activity, the case shall be deemed
automatically purged and dismissed.
By the Court,
Jerry Ward Brown, Esquire
4601 S. Clearview Dr,
Camp Hill, PA 17011
For the Plaintiff
Anne-Marie Cowden, Defendant Pro Se
548 Manor St.
Lancaster, PA 17603
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