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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '* PENNA.
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JESSICA SALISBURY,
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Plaintiff
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BRIAN E.~ALISBURY,
Defendant
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DECREE IN
DIVORCE
AND NOW, .. .. o~io.lc,.cJ ..I..... .. .... 19 .'J,.
it is ordered and
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decreed that .........".., ~~.~~~~~. .~~~~,~~~~~. . . . . . , . . . . . , , " plaintiff,
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are divorced from the bonds of matrimony.
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The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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JESSICA SALISBURY, I IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. I No. 97-3141
I
BRIAN E. SALISBURY, I CIVIL ACTION - LAW
Defendant I DIVORCE/CUSTODY
PRAECIPB TO WITHDRAW COUNTS
TO THE PROTHONOTARY:
Kindly withdraw Count II - Custody, Count III - Bxclusive
Possession of the Martial Residence, Count IV - Equitable
Distribution, and Count V - Alimony and Alimony Pendente Lite as
well as Count VI - Attorney's fees and Costs in the above
referenced divorce as the issues have been settled.
Date: ~)) q~
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Matthe J. shelman, Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
IDt 72655 Tel. (717) 763-1800
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JESSICA SALISBURY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. : No. 97-3141
:
BRIAN E. SALISBURY, : CIVIL ACTION - LAW
Defendant . DIVORCE/CUSTODY
.
PRAECIPE TO TRANSMIT RECORD
Plaintiff's
Defendant's
SStI 206-60-2371
SStI 209-62-5087
ITO the Prothonotary:
Transmit the record, together with the following information,
to the Court for entry of a divorce decree:
1. Ground for Divorce: Irretrievable breakdown under S 3301(c)
S JJOl(d) (1) of the Divorce Code. (Strike out inapplicable section)
2. Date and Manner of service of the Complaint:
IService by certified mail tI P 224 575 184 delivered
11997. See Attached Affidavit of Service.
I
I
on June 23,
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent
required by S 3301(c) of the Divorce Code: by the Plaintiff
SeDtember 18. 1998; by the Defendant SeDtember 15. 1998
(b) Date of execution of the affidavit required by S
3301(d) of the Divorce Code: ;
Date of filing of the Plaintiff's affidavit upon
the respondent: ;
Date of service of the Plaintiff's affidavit upon
the respondent:
4. Related claims pending:
None. all matters settled.
5. (Complete either paragraph (a) or (b).)
(a) Date and manner of service of the Notice of
Intention to File Praecipe to Transmit Record, a copy of which
is attached, ;
(b) Date Plaintiff's Waiver of Notice in S 3301(c)
Divorce was filed with the prothonotary: filed simultaneouslv
w/PraeciDe ;
Date Defendant's Waiver of Notice in S 3301(c)
e}~;~~i~' .'H.d with thll&th n~l'oH'd "~ltaneon"y
Matthew J. Es elman, Esquire
2108 Market treet, Aztec Building
~ Camp Hill, Pennsylvania 17011-4706
Date: (), 72 lOti 72655 Tel. (717) 763-1800
1. Attorney for the Plaintiff
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PATRICK F. LAUER. JR.
Allorney at Law
2108 Model Slim
Au", Building
Compllill, PA 17011
(717)761.1800
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JESSICA SALISBURY, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
. G'vr ,{ '7rrL"7
. Q7'3/"-/1
vs. . No.
.
.
.
BRIAN E. SALISBURY, . CIVIL ~CTION - LAW
.
Defendant . DIVORCE/CUSTODY
.
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you, and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Courthouse,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WllBRE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
JESSICA SALISBURY, I IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . No.
.
.
.
BRIAN E. SALISBURY, . CIVIL ACTION - LAW
.
Defendant . DIVORCE/CUSTODY
.
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by
law to comply with the Americans with Disabilities Act of 1990.
For information about accessible facilities and reasonable
accommodations available to disabled individuals having business
before the court, please contact our office. All arrangements must
be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 97- 3'<1 I Cv:,J I u.-
JESSICA SALISBURY,
Plaintiff
BRIAN E. SALISBURY,
Defendant
CIVIL ACTION - LAW
DIVORCE/CUSTODY
COMPLAINT
The Plaintiff, Jessica Salisbury, by and through her attorney,
Jeanne B. Wigbels, Esquire, avers the following:
1. The Plaintiff, Jessica Saliebury, is an adult individual
who currently resides at 150 Big Spring Terrace, Newville,
Cumberland County, Pennsylvania 17241.
2. The Defendant, Brian E. Salisbury, is an adult individual
whose current mailing address is 150 Big Spring Terrace, Newville,
Cumberland County, Pennsylvania 17241.
3. The Defendant, Brian E. Salisbury is currently residing
at the Friendship Hose Company No.1, located at 15 East Big Spring
Avenue, Newville, Cumberland County, Pennsylvania 17241.
4. The Defendant and the Plaintiff have been bona fide
residents of the Commonwealth of Pennsylvania for at least six
months immediately prior to the filing of this Complaint.
5. The Plaintiff and the Defendant were married on February
27, 1993 in Cumberland County, Pennsylvania.
COUNT I - DIVORCE
6. Paragraphs one (1) through five (5) are incorporated
herein by reference as if set forth specifically below.
7. There have been no prior actions of divorce or for
annulment between the parties.
8. The marriage is irretrievably broken.
9. The Plaintiff has been advised that counseling is
available and that the Plaintiff may have the right to request that
the court require the parties to participate in counseling.
10. This action is not collusive.
WHEREFORE, the Plaintiff respectfully requests this Honorable
Court grant the Plaintiff relief from the bonds of matrimony and
order a Decree in Divorce.
COUN'l' II - CUSTODY
11. Paragraphs one ( 1) through ten ( 10 ) are incorporated
herein by reference as if set forth specifically below.
12. There is one (1) dependent child by this marriage, namely
Brandy Jo Salisbury, DOB 9/28/94.
13. The Plaintiff seeks primary physical custody of Brandy Jo
Salisbury.
14. The minor child is in the custody of both Plaintiff and
Defendant.
15. The Father of the child is the Defendant, currently
residing at the above-referenced address, Paragraph Two (2).
16. The Mother of the child is the Plaintiff, currently
residing at the above-referenced address, Paragraph One (1).
17. During the past five years, the child has resided at the
following address with the following persons:
I
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i Newville, Cumberland County, Pennsylvania 17241, with Plaintiff,
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11
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March 12,
1986 until present - 150 Big Spruce 'l'errace,
Defendant, and Nicole Barrick (Plaintiff's daughter)
18.
Plaintiff reside with the following persons:
Brandy
Salisbury and Nicole Barrick.
19. Plaintiff has not participated as a party or witness, or
in another capacity, in other litigation concerning the custody of
the children in this or another court.
20. Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
21. Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child or claims to have
custody or vi&itation rights with respect to the child.
22. The best interests and welfare of the minor child will be
served by granting the relief requested because:
a. Plaintiff can provide the children with adequate
moral, emotional, and physical surroundings as required
to meet the children's needs;
b. Plaintiff is willing to continue custody of the
child.
c. Plaintiff continues to exercise parental duties and
enjoys the love and affection of the child.
23. Each parent whose parental rights to the child have not
been terminated and the person who has physical custody of the
child have been named as parties to this action.
WHEREFORE, The Plaintiff respectfully requests this Honorable
Court grant the Plaintiff rights of majority physical custody and
grant the Defendant rights of visitation.
COUNT III - EXCLUSIVE POSSESSION OF MARITAL RESIDENCE
24 . Paragraphs one ( 1) through
twenty-three (23) '~~
set forth specifically!~
incorporated herein by reference as if
below.
25. Pursuant to 23 Pa. R.C.P. S 3502(c), Plaintiff requests
that she be granted exclusive possession of the marital residence
for the following reasons:
a. The Defendant can more easily establish residence
elsewhere than the Plaintiff.
b. The Plaintiff would receive greater benefit in
remaining in the marital residence than the Defendant.
c. The parties can no longer amicably reside in the
same residence.
d. The Defendant has previously moved from the residence
and, therefore, has proved that he can establish residence
elsewhere.
e. The Plaintiff is raising two children (one of which
the Defendant is the father), and the children should continue
to remain in the marital home with Plaintiff, their mother.
WHEREFORE, the Plaintiff, Jessica Salisbury, respectfully
requests that this Honorable Court grant her the exclusive right to
reside in the marital residence, with the furniture and household
items therein, until such time as this Court may make a final Order
of Divorce and Equitable Distribution.
COUNT IV - EOUITABLE DISTRIBUTION
26. Paragraphs one (1) through twenty-five (25) are
incorporated herein by reference as if set forth specifically
below.
27. The parties have legally and beneficially acquired
property, both real and personal, during their marriage.
28. The Plaintiff and the Defendant have been unable, as of
the date of this Complaint, to agree as to an equitable division of
said property.
COUNT V - ALIMONY AND ALIMONY PENDENTE LITE
29. Paragraphs one (1) through twenty-eight (28) are
incorporated herein by reference as if set forth specifically
below.
30. Plaintiff is the dependent epouse. The Plaintiff lacks
sufficient property to provide for her reasonable means is unable
to support herself completely through appropiate employment.
31. The Plaintiff requires reasonable support to adequately
maintain herself in accordance with the standard of living
establiehed during the marriage.
COUNT VI - ATTORNEY'S FEES AND COSTS
32. Paragraphs one (1) through thirty-one (31) are
incorporated herein by reference as if set forth specifically
below.
33. The Plaintiff has entered into a fee agreement with her
attorney.
34. The Plaintiff may be in need of hiring an accountant, a
real estate appraiser, and other experts and does not have the
funds required to pay the neceesary and reasonable fees.
WHEREFORE, the Plaintiff, Jessica Salisbury, respectfully
requests this Honorable Court to equitably divide all marital
property and to enjoin it from being removed, disposed of,
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JESSICA SALISBURY, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . No. 97-3141
.
.
.
BRIAN E. SALISBURY, : CIVIL ACTION - LAW
Defendant . DIVORCE/CUSTODY
.
PLAINTIFF'S WAIVER OF NOTICE OJ!' INTENTION
TO REQUEST ENTRY OJ!' A DIVORCE DECREE
UNDER SECTION 330l(cl OJ!' THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees, or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the prothonotary.
I 4. I verify that the statements made in this affidavit are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. S 4904 relating to
unsworn falsification to authorities.
DATE:
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JESSICA SALISBURY, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I No. 97-3141
:
BRIAN E. SALISBURY, . CIVIL ACTION - LAW
.
Defendant . DIVORCE/CUSTODY
.
DEP'BNDANT'S AFFIDAVIT OJ!' CONSENT
UNDER SECTION 3301(cl OJ!' THE DIVORCE CODE
1. A complaint in divorce under Section 330l(c) of the
Divorce Code was filed on June 12, 1997.
2. The marriage of the Plaintiff and the Defendant is
irretrievably broken and ninety days have elapsed from the date of
filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
4. I verify that the statements made in this affidavit are
true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. S 4904 relating to
unsworn falsification to authorities.
DATE: 3~ I~ - 'i ~
Signature:
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4, Father shall notify Mother atleastlwenty-four (24) hours prior to his
partial physical custody if he shall be unable to exercise said custody as provided for
herein,
5, The parties will keep each other advised immediately relative to any
emergencies concerning the child and shall further take any necessary steps to ensure
that the health and well being of the child is protected,
6, Neither parent shall do anything which may estrange the child from the
other party, or injury the opinion of the child as to the other party, or which may hamper
the free and natural development of the child's love or affection for the other party.
7. Any modification or waiver of any of any the provision of this Agreement
shall be effective only if made in writing and only if executed with the same formality as
this Stipulation and Agreement.
8, It is intended that this Agreement will be modified in the future when
Father is able to obtain more permanent housing,
9, The parties desire that this Stipulation and Agreement be made an Order
of Court to the Court of Common Pleas of Cumberland County, and further
acknowledge that the Court of Common Pleas of Cumberland County does, in fact,
have jurisdiction over the issue of custody of the parties' minor child and shall retain
such jurisdiction should circumstances change and either party desire or require
modification of said Order,
10. The parties agree that in making this Agreement, there has been no
fraud, concealment, overreaching, coercion or other unfair dealing on the part of the
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JESSICA SALISBURY,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
I CUMBBRLAND COUNTY, PBNNSYLVANIA
: No. q1-JIJ.lI {L,tT~
I (') .0 0
I CIVIL ACTION - LAW -J '11
: DIVORCB/CUSTOD1ffi~'~ ~ ;~;g
i!Z,:.. 'n~
61;, N "';6
NOTICE TO DEI!'BND AND CLAIM RIGHTS ~~: :!? :;; :H
You have been sued in court. If you wish tdl~~fe;d ~~~nst
the claims set forth in the following pages, you mu~ tJke~rompt
action. You are warned that if you fail to do so, the case may
proceed without you, and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered
I, against you for any other claim or relief requested in these papers
Ilby the Plaintiff. You may lose money or property or other rights
I important to you, including custody or visitation of your children.
I When the ground for the divorce is indignities or
I irretrievable breakdown of the marriage, you may request marriage
"
II counseling. A list of marriage counselors is available in the
II Office of the Prothonotary at the Cumberland County Courthouse,
I,carlisle, Pennsylvania.
I! IF YOU DO NOT FILB A CLAIM FOR ALIMONY, DIVISION OF PROPBRTY,
I LAWYBR'S FEES OR EXPENSBS BBFORE A DIVORCE OR ANNULMENT IS GRANTED,
. YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THBM.
vs.
BRIAN B. SALISBURY,
Defendant
YOU SHOULD TAKE THIS PAPBR TO YOUR LAWYER AT ONCE. IF YOU DO
I NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
: I OFFICE SET I!'ORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
"
i' COURT ADMINISTRATOR
: 1 CUMBERLAND COUNTY COURTHOUSE
il CARLISLE, PA 17013
II (717) 240-6200
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annulment between the parties.
8. The marriage is irretrievably broken.
9. The Plaintiff has been advised that counseling is
available and that the Plaintiff may have the right t~request that
the court require the parties to participate in counseling.
10. This action is not collusive.
'WHEREFORE, the Plaintiff respectfully requests this Honorable
Court grant the Plaintiff relief from the bonds of matrimony and
order a Decree in Divorce.
"
II
COUNT II - CUSTODY
11. Paragraphs one (1) through ten (10) are incorporated
herein by reference as if set forth specifically below.
II 12. There is one (1) dependent child by this marriage, namely
II Brandy Jo Salisbury, DOB 9/28/94.
I'
'I 13. The Plaintiff seeks primary physical custody of Brandy Jo
Salisbury.
14. The minor child is in the custody of both Plaintiff and
Defendant.
15.
The Father of the child is the Defendant, currently
at the above-referenced address, Paragraph Two (2).
The Mother of the child is the Plaintiff, currently
at the above-referenced address, Paragraph One (1).
During the past five years, the child has resided at the
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following address with the following persons:
March 12, 1986 until present - 150 Big Spruce Terrace,
Newville, Cumberland County, Pennsylvania 17241, with Plaintiff,
.!
Defendant, and Nicole Barrick (Plaintiff's daughter)
18. Plaintiff reside with the following persons I Brandy
Salisbury and Nicole Barrick.
19. Plaintiff has not participated as a party or witness, or
in another capacity, in other litigation concerning the custody of
the children in this or another court.
20. Plaintiff has no information of a custody proceeding
concerning the child pending in a court of this Commonwealth.
21. Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child or claims to have
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custody or visitation rights with respect to the child.
22. The best interests and welfare of the minor child will be
served by granting the relief requested because:
a. Plaintiff can provide the children with adequate
moral, emotional, and physical surroundings as required
to meet the children's needs;
b. Plaintiff is willing to continue custody of the
child.
c. Plaintiff continues to exercise parental duties and
enjoys the love and affection of the child.
23. Each parent whose parental rights to the child have not
. been terminated and the person who has physical custody of the
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:;child have been named as parties to this action.
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:11 WHEREFORE, The Plaintiff respectfully requests this Honorable
: Court grant the Plaintiff rights of majority physical custody and
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.jgrant the Defendant rights of visitation.
COUNT III - EXCLUSIVE POSSESSION OJ!' MARITAL RESIDENCE
24. Paragraphs one (1) through twenty-three (23) are
'i incorporated herein by reference as if set forth specifically
requests that this Honorable Court grant her the exclusive right to
,I reside in the marital residence, with the furniture and household
II items therein, until such time as this Court may make a final Order
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i of Divorce and Equitable Distribution.
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I,
II
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below.
25. Pursuant to 23 Pa. R.C.P. S 3502(c), Plaintiff requests
that she be granted exclusive possession of the marital residence
for the following reasons I
a. The Defendant can more easily establish residence
elsewhere than the Plaintiff.
b. The Plaintiff would receive greater benefit in
remaining in the marital residence than the Defendant.
c. The parties can no longer amicably reside in the
same residence.
d. The Defendant has previously moved from the residence
and, therefore, has proved that he can establish residence
elsewhere.
e. The Plaintiff is raising two children (one of which
the Defendant is the father), and the children should continue
to remain in the marital home with Plaintiff, their mother.
WHEREFORE, the Plaintiff, Jessica Salisbury, respectfully
COUNT IV - EOUITABLB DISTRIBUTION
26.
twenty-five
are
(25)
through
Paragraphs
(1)
one
: I incorporated herein by reference as if set forth specifically
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:i below.
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i 27.
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d
The parties have legally and beneficially acquired
property, both real and personal, during their marriage.
28. The Plaintiff and the Defendant have been unable, as of
the date of this Complaint, to agree as to an equitable division of
said property.
COUNT V - ALIMONY AND ALIMONY PENDENTE LITE
29. Paragraphs one (1) through twenty-eight (28) are
incorporated herein by reference as if set forth specifically
below.
30.
Plaintiff is the dependent spouse.
The Plaintiff lacks
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;, sufficient property to provide for her reasonable means is unable
il
, to support herself completely through appropiate employment.
31. The Plaintiff requires reasonable support to adequately
maintain herself in accordance with the standard of living
ilestablished during the marriage.
"
!I COUNT VI - ATTORNEY'S I!'BES AND COSTS
!I
I 32. Paragraphs one (1) through thirty-one (31) are
I
incorporated herein by reference as if set forth specifically
below.
33. The Plaintiff has entered into a fee agreement with her
f I attorney.
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I' 34. The Plaintiff may be in need of hiring an accountant, a
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i real estate appraiser, and other experts and does not have the
,;funds required to pay the necessary and reasonable fees.
,
WHEREFORE, the Plaintiff, Jessica Salisbury, respectfully
requests this Honorable Court to equitably divide all marital
: property and to enjoin it from being removed, disposed of,
,
:'
JESSICA SALISBURY,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 97-3141 CIVIL TERM
CIVIL ACTION - LAW
DIVORCE/CUSTODY
BRIAN E. SALISBURY,
Defendant
PLAINTII!'I!"S PETITION !!'OR EXCLUSIVE POSSESSION
OJ!' THE MARITAL RESIDENCE
The Plaintiff, Jessica Salisbury, by and through her attorney,
Jeanne B. Wigbels, Esquire, avers the following:
1. The Plaintiff, Jessica Salisbury, is an adult individual
who currently resides at 150 Big Spring Terrace, Newville,
Cumberland County, Pennsylvania 17241.
2. The Defendant, Brian E. Salisbury, is an adult individual
whose current mailing address is 150 Big Spring Terrace, Newville,
Cumberland County, Pennsylvania 17241.
3. The Defendant, Brian E. Salisbury is currently residing
at the Friendship Hose Company No.1, located at 15 East Big Spring
Avenue, Newville, Cumberland County, Pennsylvania 17241.
4. Pursuant to 23 Pa. R.C.P. S 3502(c), Plaintiff requests
that she be granted exclusive possession of the marital residence
for the following reasons:
a. The Defendant can more easily establish residence
elsewhere than the Plaintiff.
b. The Plaintiff would receive greater benefit in
remaining in the marital residence than the Defendant.
c. The parties can no longer amicably reside in the
same residence.
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VERIFICATION
I verify that the statements made in the foregoing Petition To Modify Custody
are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities,
DATED: /-d6 ....7'7
4, Father shall notify Mother etleast twenty-four (24) hours prior to his
partial physical custody if he shall be unable to exercise said custody as provided for
herein.
5. The parties will keep each other advised immediately relative to any
emergencies concerning the child and shall further take any necessary steps to ensure
that the health and well being of the child is protected.
6. Neither parent shall do anything which may estrange the child from the
other party, or injury the opinion of the child as to the other party, or which may hamper
the free and natural development of the child's love or affection for the other party.
7. Any modification or waiver of any of any the provision of this Agreement
shall be effective only if made in writing and only if executed with the same formality as
this Stipulation and Agreement.
8, It is intended that this Agreement will be modified in the future when
Father is able to obtain more permanent housing,
9, The parties desire that this Stipulation and Agreement be made an Order
of Court to the Court of Common Pleas of Cumberland County, and further
acknowledge that the Court of Common Pleas of Cumberland County does, in fact,
have jurisdiction over the issue of custody of the parties' minor child and shall retain
such jurisdiction should circumstances Change and either party desire or require
modification of said Order.
10, Tha parties agree that in making this Agreement, there has been no
fraud, concealment, overreaching, coercion or other unfair dealing on the part of the
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,----
PATRICK F. LAUER, JR.
Allomey at Law
2108 Market Street
Aztec Building
Camp Hill, PA 17011
l.8w 0Ibe of
Palricl( F Lauer, J;,
2108 Mmet SI.
Camp HIJ, PA 1701
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PATRICK F. LAUER, JR.
Allomey at Law
2108 Market Street
Aztec Building
Camp Hill. PA 17011
law Ofbs of
Patrick F lauer, Jr,
2108 MEflt91 81.
Camp HII, PA 1701
. --'--'-'---~"~-'
PATRICK F. LAUER, JR.
Allomey at Law
2108 Market Street
Aztee Building
Camp Hill, PA 17011
BRIAN E. SALISBURY
150 BIG SPRING TERRACE
NEWVILLE, PA 17241