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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
PENNA.
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MONA W. HUSTON,
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No.
00-7995 Civil Term
Plaintiff
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VERSUS
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ROBERT G. HUSTON,
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Defendant
IN DIVORCE
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DECREE IN
DIVORCE
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AND NOW,_p()\)t1......,~P:r- IS
, 200 I , IT IS ORDERED AND
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DECREED THAT
MONA W. HUSTON
, PLAINTIFF,
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AND
ROBERT G. HUSTON
, DEFENDANT,
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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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None.
The Marital Settlement Agreement dated October 25, 2001
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is incorporated but not merged into this Decree in Divorce.
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MONA W. HUSTON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 00-7995 CIVIL TERM
v.
ROBERT G. HUSTON,
Defendant
: IN DIVORCE
MARITAL SETTLEMENT AGREEMENT
THIS MARITAL SETTLEMENT AGREEMENT is made this 2.S day of October, 2001, by
and between MONA W, HUSTON, ("Wife"), and ROBERT G. HUSTON, ("Husband").
WHEREAS, the parties were married on January 11, 1986, and have remained married
since that time; and
WHEREAS, the parties are the parents of four children born to their marriage; and
WHEREAS, certain differences have arisen between the parties and, as a consequence,
they are living separate and apart from each other; and
WHEREAS the parties wish to set forth certain covenants and understandings regarding
their separation, custody of their children, and their respective property rights;
NOW THEREFORE, in consideration of the mutual promises and undertakings contained
herein, the parties hereto, intending to be legally bound, covenant and agree as follows:
1. VOLUNTARY AGREEMENT: The parties agree that this Marital Settlement
Agreement is entered into voluntarily and after due deliberation by each of them. The execution of
the Agreement is not the result of any duress of undue influence, and it is not the result of any
collusion or improper illegal agreement or agreements. The parties acknowledge that each has
been fully informed of, or is familiar with, the wealth, property, state, and income of the other, and
each party is hereby satisfied that such information is true and correct.
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2. LEGAL ADVICE: The parties acknowledge that Wife has been represented by
Andrea C. Jacobsen, Esquire, in this matter, and Husband is unrepresented by counsel in this
matter. Wife and Husband each acknowledge that they have received, or have had the opportunity
to receive independent legal advice from counsel of her or his selection prior to the execution of
this Agreement. Each party agrees that she or he each fully understands the facts surrounding this
divorce, and each has had the opportunity to be fully informed as to her or his legal rights and
obligations. Each party acknowledges and accepts that this Agreement is, under the
circumstances, fair and equitable, and that it is being entered into freely and voluntarily after Wife's
consultation with her attorney and Husband's review of this agreement.
3. SEPARATION AND NON-INTERFERENCE: It shall be lawful for Wife and
Husband at all times hereafter to live separate and apart from each other and to reside from time to
time at such place or places as they shall respectively deem fit, free from any control, restraint,
harassment or interference, indirect or direct, from each other. The foregoing provisions shall not
be taken to be an admission on the part of either party of the lawfulness or unlawfulness of the
causes leading them to live apart.
4. DIVORCE ACTION: An action for divorce between the parties has been filed by
Wife in the Court of Common Pleas of Cumberland County, Pennsylvania, to the caption, Huston
v. Huston, No. 2000-7995 Civil Term. The parties hereby acknowledge their intention and
agreement to proceed in said action to obtain a final decree in divorce by mutual consent under
Section 3301(c) of the Pennsylvania Divorce Code on the grounds that their marriage is
irretrievably broken, and to settle, amicably and fully hereby, all claims which might be raised by
either party in the divorce action. The parties acknowledge that they are executing, simultaneous
with the signing of this Marital Settlement Agreement, the necessary Affidavits of Consent and
Waivers of Notice of Intention to Request Entry of a Divorce Decree in the pending action.
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5. CUSTODY: The parties are the parents of four children: Hollis G Huston, born April
23, 1983; Hayley R. Huston, born September 24, 1987; Hyder W. Huston, born April 24, 1995; and
Hattie H. Huston, born October 29, 1997. The children are presently residing with Wife and have
been in her physical custody since the parties separated. The parties have agreed that it is in the
best interest of their minor children, under the circumstances, for the parties to agree to the entry of
a court order awarding themselves shared legal custody of their minor children; awarding Wife
primary physical custody of the parties' minor children; and awarding Husband partial custody for
the purpose of visitation on a liberal schedule as may be agreed between the parties. The parties
acknowledge that they are executing, simultaneous with the signing of this Marital Settlement
Agreement, a Stipulation for the entry upon consent of such a Custody Order.
6. CHILD SUPPORT: The parties acknowledge their interest in the well-being of their
children and their obligation to provide for their support. The parties agree that pending Court
Order to the contrary, Husband shall pay Wife, as primary custodian of the children, the sum of
TWO HUNDRED FIFTY DOLLARS ($250.00) per week for the support of their children, or such
greater sum as may be payable under law, or as the parties may agree. The partieS have set this
sum on the basis of their respective incomes and earning capacities and in consideration of the
childcare expenses and health insurance costs incurred on behalf of the children. They agree that
in the event of a modification of such expenses they will review and modify the amount of the
support as appropriate. They agree that it is their intent that such payments shall be made directly
by Husband to Wife and not through any Court unless Husband shall fail to comply with his
obligation, in which case, upon application of Wife, such payments, or such greater amounts as
may be due under the applicable law, shall be payable through the Domestic Relations Section of
the Court of Common Pleas of Cumberland County. The parties agree to execute any necessary
documents or to otherwise cooperate to effectuate the intent of this paragraph.
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7. MARITAL REAL PROPERTY: Wife currently resides in the home purchased by
the parties at 2139 Circle Road, Carlisle, Pennsylvania, and has maintained her residence in the
home since the separation of the parties. Wife agrees to accept responsibility for any debts or
obligations stemming from her current occupancy of the home including any current unpaid real
estate taxes, utilities, assessments, and any other obligations directly accruing from the ownership
and occupancy and to hold Husband harmless from any responsibility for such expenses incurred
and unpaid since their separation. The parties acknowledge that they are executing, simultaneous
with the signing of this Marital Settlement Agreement, a Deed for the conveyance of the marital real
property to Wife whereby Husband is conveying to Wife any and all interest he has in the marital
real estate.
8. PERSONAL PROPERTY: The parties acknowledge that there has been
distribution of their items of personal, tangible and intangible property, between them since their
separation, and, except as otherwise provided for herein, or as may be mutually agreed upon by
the parties, each agrees that the division of such property is to their mutual satisfaction, subject to
the further terms of this Marital Settlement Agreement. Except as otherwise provided for within this
Marital Settlement Agreement, each of the parties shall hereafter own and enjoy, independently of
any claim or right of the other party, all items of personal, tangible and intangible property now or
hereafter owned or held by her or him with full power to dispose of the same effectively and for all
purposes as if she or he were unmarried.
The parties acknowledge that except as provided for herein, Husband has removed all his
personal property from the marital home, and has no further claim or interest in any of the contents
of the premises.
9. VEHICLES: The parties acknowledge that they have divided between them the
personal vehicles that they own, and that the current possession of the vehicles is to their mutual
satisfaction. The parties agree that hereinafter each shall retain full title, right and interest in the
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vehicle or vehicles in their possession, without interest or claim of any right of the other party. The
parties agree to execute any necessary titles or other documents or to otherwise cooperate to
effectuate the intent of this paragraph.
10. RETIREMENT ACCOUNTS: Husband is the owner of two retirement accounts,
which were acquired during their marriage and constitute marital property: AG Edwards Roth IRA
Account No. 0475-039874; and AG Edwards IRA Account No. 0475-023374. The parties certify
that there have been no withdrawals from such accounts by either party since the date of their
separation. The parties further certify that such accounts are the only retirement, pension or
deferred income accounts owned by either party. The parties agree that Husband shall retain full
and complete title and ownership of the said retirement accounts, and Wife hereby waives and
releases any and all claim or interest she may have in such accounts. Wife agrees to execute any
necessary documents or to otherwise cooperate to effectuate the intent of this paragraph.
11. INVESTMENT ACCOUNTS: The parties are the joint owners of an investment
account that was acquired during their marriage and constitutes marital property: AG Edwards
Account No. 4675-064267-012. The parties certify that there have been no withdrawals from such
accounts by either party since the date of their separation. The parties certify that except for the
custodial account maintained for the benefit of their son, Hollis, such account is the only investment
account, owned by either party. The parties agree that the parties shall divide the assets in the
said account by mutual consent so that each party shall enjoy ownership of FIFTY PERCENT
(50%) of the value of the account on the date of division. The parties agree to execute any
necessary documents or to otherwise cooperate to effectuate the intent of this paragraph.
12. BANK ACCOUNTS: The parties agree that they are the owners of a joint checking
account through M & T Bank. The parties certify that except for the Tangles business checking
account maintained by Wife, and a personal checking account maintained by Husband, this is the
only bank account owned by either party, individually or jointly with any other person. The parties
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agree that Wife shall retain full and complete title and ownership of the said bank account, and
Husband hereby waives and releases any and all claim or interest he may have in such acCounts.
Husband agrees to execute any necessary documents or to otherwise cooperate to effectuate the
intent of this paragraph.
13. TANGLES HAIR SALON: The parties acknowledge that Wife is the owner of
Tangles Hair Salon and the checking account, good will, equipment and inventory maintained by
the business. The parties agree that Wife shall retain full and complete title and ownership of the
said business, and Husband hereby waives and releases any and all claim or interest he may have
in such business. Wife hereby indemnifies and holds Husband harmless with regard to any debts
or obligations of the business or associated with the operation of the business, which presently
exist or may exist in the future. The parties agree to execute any necessary documents or to
otherwise cooperate to effectuate the intent of this paragraph.
14. MOTORCYCLE BUSINESS: The parties acknowledge that Husband is the owner
of an inventory of motorcycles and business interests related to the sale of motorcycles. The
parties agree that Husband shall retain full and complete title and ownership of the said business,
and Wife hereby waives and rele!lses any and all claim or interest she may have in such business.
Husband hereby indemnities and holds Wife harmless with regard to any debts or obligations of the
business or associated with the operation of the business, which presently exist or may exist in the
future. The parties agree to execute any necessary documents or to otherwise cooperate to
effectuate the intent of this paragraph.
15. LIFE NSURANCE: The parties agree that Wife is the owner of an insurance policy
issued through Mutual of Omaha with current cash value of approximately $2,748.00. The parties
agree that Wife shall retain full and complete title and ownership of the said policy, and Husband
hereby waives and releases any and all claim or interest he may have in such policy.
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16. EXECUTION OF DOCUMENTS: Each of the parties shall, from time to time at the
request of each other, execute, acknowledge and deliver to the other party any and all further
instruments that may reasonably be required in order to give full force and effect to the provisions
of this Agreement.
17. TAXES: Wife and Husband warrant that they have paid all taxes on prior jointly
filed retums including the calendar year ending December 31, 2000; that they do not owe any
interest or penalties; and that no tax deficiency proceeding or audit is pending or notice thereof
received. Husband shall give Wife notice of any deficiency assessment and Wife shall give
Husband notice of any deficiency assessment of which they individually or collectively become
aware. The parties agree that should it ultimately be determined that any deficiency and/or penalty
exists with respect to any jointly filed retums, the party responsible for the erroneous preparation
and/or, non-disclosure or erroneous disclosure of information which has resulted in the deficiency
and/or penalty, shall be solely responsible for the payment of the amount ultimately determined to
be due, together with interest, as well as expenses that may be incurred to contest the
assessment.
18. MUTUAL RELEASE AND COUNSEL FEES: Except as provided for in this
Agreement, the parties hereby remise, release, quit-claim and forever discharge each other and
the estate of each other, for all time to come, and for all purposes whatsoever, from any and every
c1aim,including alimony, alimony pendente lite, spousal support, equitable distribution of marital
property, counsel fees or costs under the Divorce Reform Act, or otherwise, that they make or
hereafter make in and to or against each other's estates or any parts thereof, whether by way or
dower or courtesy, or under the intestate laws, or the right to take or elect against the other's will,
except only such rights as accrue pursuant to this Agreement.
19. ENTIRE AGREEMENT: The parties acknowledge and agree that this Agreement
contains the entire understanding of the parties and supersedes any prior agreement between
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them. There are no other representations, warranties, promises, covenants or understandings
between the parties other than those expressly set forth herein.
20. AGREEMENT BINDING ON HEIRS AND ASSIGNS: This Agreement constitutes
the final agreement of the parties and is binding upon their heirs, assigns and successors in
interest.
21. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall
be determined or declared to be void or invalid in law or otherwise, then only that term, condition,
clause or provision shall be stricken from this Agreement, and in all other respects this Agreement
shall be valid and continue in full force, effect and operation.
22. APPLICABLE LAW: This Agreement shall be construed under the laws of this
Commonwealth of Pennsylvania.
23. BREACH OF AGREEMENT: In the event that either party breaches any provision
of this Agreement or fails to timely perform his or her obligation under this Agreement, she or he
shall be responsible for any and all costs incurred to enforce the Agreement, including, but not
limited to, court costs and counsel fees of the other party. In the event of breach, the other party
shall have the right, at her or his election, to sue for damages for such breach or to seek such other
and additional remedies as may be available to her or him.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals as of the day
and year first above written.
{lJtou~~
MO W. HUSTON
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ROBERT G. HUSTON
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-7995 CIVIL TERM
: IN DIVORCE
MONA W. HUSTON,
Plaintiff
ROBERT G. HUSTON,
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for the divorce is irretrievable breakdown under Section of 3301 (c) of the
Divorce Code.
2. Defendant was served the Divorce Complaint on or about November 13, 2000.
3. Plaintiff's Affidavit required by Section 3301 (c) of the Divorce Code was executed
by the Plaintiff on October 25, 2001.
4. Defendant's Affidavit required by Section 3301(c) of the Divorce Code was
executed by the Defendant on October 25, 2001.
5. There are no related claims pending. The parties agree to the entry of the Marital
Settlement Agreement dated October 25, 2001, to be incorporated into the final Decree of Divorce
between them.
Respectfully submitted,
1\ \0.5 j 2<::0 I
Me
Andrea C. J en, Esquire
52 E. High Street
Carlisle, PA 17013
(717) 249-1705
Attorney for Plaintiff
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MONA W. HUSTON
PLAINTIFF
V.
ROBERT G. HUSTON
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-7995 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 17th day of November, 2000, upon consideration of the attached Complaint,
it is hereby directed that the parties and their respective counsel appear beforeMelissa P. Greevy, Esq. ,the conciliator,
at 214 Senate Avenue, Suite 105, Camp Hill, P A 17011 on the 13th day of December , 2000, at .-l=00 p.m.
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
ifthis cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
FOR THE COURT,
By: Isl
Melissa P. Greevy. Esq. t/J
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990, For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Xvenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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MONA W. HUSTON,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00- 79'h,'" CIVIL TERM
ROBERT G. HUSTON,
Defendant
: IN DIVORCE
ORnRR
AND NOW, this _ day of
,2000 upon consideration of the attached
Complaint, it is hereby directed that the parties and their respective counsel appear
before
, the Conciliator, at
, on the _day of
_, 2000, at __ o'clock _.m., for a Pre-Hearing Custody Conference. At such
conference, an effort will be made to resolve the issues in dispute; or if this cannot be
accomplished, to define and narrow the issues to be heard by the Court, and to enter
into a temporary order. Failure to appear at the conference may provide grounds for
entry of a temporary or permanent order.
FOR THE COURT,
By:
Custody Conciliator
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MONA W. HUSTON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00- 1'195"
CIVIL TERM
ROBERT G. HUSTON,
Defendant
: IN DIVORCE
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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
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 SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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MONA W. HUSTON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00- 79'15"
CIVIL TERM
ROBERT G. HUSTON,
Defendant
: IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I - DIVORCE
1. Plaintiff is MONA W. HUSTON, presently residing at 2139 Circle Road, Carlisle,
Cumberland County, Pennsylvania, 17013.
2. Defendant is ROBERT G. HUSTON presently residing at 2139 Circle Road,
Carlisle, Cumberland County, Pennsylvania, 17013.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. Plaintiff and defendant were married January 11, 1986.
5. There have been no prior actions of divorce or for annulment between the parties
in this or any other jurisdiction.
6. Neither party to this action in divorce is currently a member of the Armed Forces
of the United States of America.
7. 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.
8. The marriage between the parties hereto is irretrievably broken.
9. Plaintiff requests the Court to enter a decree of divorce.
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COUNT II - CHILD CUSTODY
10. Plaintiff incorporates herein the prior paragraphs by reference.
11. Plaintiff seeks a court order awarding her shared legal and primary physical custody
of the parties' children: Hollis G Huston, born April 23, 1983; Hayley R. Huston, born September
24, 1987; Hyder W. Huston, born April 24, 1995; and Hattie H. Huston, born October 29, 1997,
with whom she is presently residing. The children were born to the marriage of the parties.
12. The children are presently in the physical custody of plaintiff (Mother).
13. During the last five years, the children have resided with the parties at 2139 Circle
Road, Carlisle, Cumberland County, PA, 17013.
14. 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.
15. Plaintiff has no information of a custody proceeding concerning the children pending
in a court of this Commonwealth.
16. Plaintiff does not know of a person not a party to the proceedings who has physical
custody of the children or claims to have custody or visitation rights with respect to the children.
17. Plaintiff believes that she is best able to provide a stable loving home for her children
and that their best interest and permanent welfare will be served by granting the relief request
and awarding her primary physical custody of the children, granting defendant (Father) partial
physical custody for visitation and granting the parties shared legal custody of the child.
18. Each parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child has been named as parties to this action.
19. Plaintiff request this Court to enter an Order granting the parties shared legal custody
of the children, and granting her primary physical custody of the children subject to the grant of
partial physical custody to defendant.
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COUNT 111- EQUITABLE DISTRIBUTION
20. Plaintiff incorporates the prior paragraphs by reference.
21. The parties are the owners of real and personal property subject to equitable
distribution between them as marital property.
22. Plaintiff requests the Court to equitably divide such items of marital property between
them.
WHEREFORE, the Plaintiff requests this Court to:
a. Enter a final Decree of Divorce divorcing plaintiff from defendant;
b. Award the parties shared legal custody of their minor children and award
plaintiff primary physical custody of the parties' minor children subject to partial
custody for visitation with the defendant; and
c. Grant equitable distribution of the marital property of the parties; and
d. Grant such further relief as this Court may deem proper and just.
Respectfully submitted,
h\ \3 \ 00
BY: Andre C acobsen
JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
(717) 249-6427 - Telephone
(717) 249-8427 - Fax
Attorney No. 20952
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VERIFICATION
I hereby verify that the statements made in the foregoing Complaint In Divorce are true
and correct. I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904, relating to unsworn falsification to authorities.
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-{9'95"
CIVIL TERM
ROBERT G. HUSTON,
Defendant
: IN DIVORCE
WAIVER OF COUNSELING
MONA W. HUSTON, plaintiff herein, hereby states and certifies as follows:
1. I have been advised of the availability of marriage counseling and understand
that I may request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the
Domestic Relations Office, which list is available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904, relating to unsworn falsification to authorities.
Dated: II 113100
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Plaintiff
PENNSYLVANIA
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
v.
: NO. 00-7995
CIVIL TERM
ROBERT G. HUSTON,
Defendant
: IN DIVORCE
CERTIFICATE OF SERVICE
I, Shelley Eichelberger, hereby certify that a certified copy of the
Complaint in Divorce in the above captioned matter was duly served upon the
Defendant, Robert G. Huston, by depositing it in the U.S. Mail, certified,
restricted delivery, return receipt requested, on November 13, 2000, addressed
as follows:
Robert G. Huston
2139 Circle Road
Carlisle,PA 17013
I hereby verify that the statements made in the foregoing are true and
correct. I understand that false statements herein are made subject to the
penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to
authorities.
And further that this attached card demonstrates that on November 14,
2000, the Defendant was served.
DATE: /1 )IS/DO
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SHELL EICHELBER R
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MONA W. HUSTON,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-7995 CIVIL TERM
ROBERT G. HUSTON,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under the Divorce code was filed November 13, 2000, on
the grounds that the marriage of the parties is irretrievably broken.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in the Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating
to unsworn falsification to authorities.
Date: Ott <':", LCO I
'fZZt'M 11/ IJI~
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MONA W. HUSTON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-7995 CIVIL TERM
ROBERT G. HUSTON,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
~4904 relating to unsworn falsification to authorities
Date: /f'\
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If'r2DJut ~ I))MJ7u-
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MONA W. HUSTON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-7995 CIVIL TERM
ROBERT G. HUSTON,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under the Divorce code was filed November 13, 2000, on
the grounds that the marriage of the parties is irretrievably broken.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in the Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating
to unsworn falsification to authorities.
Date:
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MONA W. HUSTON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-7995 CIVIL TERM
ROBERT G. HUSTON,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
94904 relating to unsworn falsification to authorities
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MONA W. HUSTON,
Plaintiff,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
No. 00-7995 Civil Action - Law
ROBERT G. HUSTON,
Defendant.
In Custody
ORDER OF COURT
AND NOW, this 14th day of December, 2000, the Conciliator, being advised by
Plaintiffs counsel that the parties have reconciled, hereby relinquishes jurisdiction in this case.
FOR THE COURT,
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