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HomeMy WebLinkAbout01-03836 E. L! I~ _, 'd '" "_ -' -' ~--, . SUSAN J. MURRAY PLAINTIFF V. PETERD.MURRAY DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA 01-3836 CIVIL ACTION LAW IN CUSTODY ORDER OF COlJRT AND NOW, Tuesday, Juue 26, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawu S. Suuday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, July 11, 2001 at 10:00 a.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. 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. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday. Esq.~ 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 HA VB 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 Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 - ~ -. . ?c)lfCJ( u'XtJ! t,';2~#( ~~, <<, '.> ' u-." '''/__'.~'=''', ,< '.r' ,,,.,. , "'""~'''' ~,,,..,,...,,.,,,',..,' r'i'!ii""j~'1mw .'[nnr, Ii l.J._'r'I"'J'''I'I~ [~; >.,11.\::;~1;:~ i\:,IU:?O ~U'l.i'" , '" 1"-'" L '~il,-" I I "( i, ,\i j ( v ,..".."'~", ",",-,'..:l ~ I PE~JNSYLVPN1A w.... t~ ~ -d.... "~ . ~ Cj//~ ~ $ 6l! .~~ zia:1c~ _"I'.....,,~ """'~..-. ..,"., I ..,.~~ _ ~ ,.,~~~~,I~_~ ~,0I,f'1!!IlI'I~_~I,T] JiII-,11W.">jj"~'~~"'"'f'C,,+,"',i~h'~~";'i'.," -,,"'-',," . -'-'W] "',", ""M~~'I~'~~I!i!l'i~I!'~li-M~!>lfrr:tjjr,jh""PF-f\!i'11~lJIlIi!!(~Jr\i~ -- '. ~ ~~ ,_ J,u -'I,,J.,,,,. '" '" ~, " "--..: ; 5 JUN 2 52D:DIf;/) Theresa Barrett Male Supreme Court #46439 513 North Second Street Harrisburg, PA 17101 (717) 233.3220 Counsel For Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN J. MURRAY, Plaintiff v. 01- 0 1- ,;1'.31::. Gu lL~~ PETER D. MURRAY, Defendant CIVIL ACTION - DIVORCE/CUSTODY ORDER OF COURT AND NOW, this day of June, 2001, upon consideration of the attached Complaint for Divorce and Custody, it is hereby directed that the parties and their respective counsel appear before the Conciliator: at on , 2001 at .m. for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute or, if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older may also be present at the Conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. - . '", -,,' l h,J",",' ,'",,,~~, "'-'~lrlIIiillii_:.; For the Court, Date of Order: By: Custody Conciliator YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 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. BY THE COURT: J. 2 - ~- " Theresa Barrett Male Supreme Court #46439 513 North Secoud Street Harrisburg, PA 17101 (717) 233.3220 Couusel For Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN J. MURRAY, Plaintiff v. 01-0/- 3'6'3(, Cw.JJ~ PETER D. MURRAY, Defendant CIVIL ACTION - DIVORCEICUSTODY 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 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, South Hanover Street, 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 - ",~ .~,~~ ,- '" 1...01: \c ;.".' <"" ,,,.~~,,~,:: 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. BY THE COURT: J. 2 ~ " , ." ,,! 1, - "'~', _ , ,', ,tJ , '-; " ' '". -~-"";.;""'-";,: Theresa Barrett Male Supreme Court #46439 513 North Second Street Harrisburg, PA 17101 (717) 233.3220 Counsel For Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN J. MURRAY Plaintiff v. 01- 3f3c. C.iiHJ "/.u- PETER D. MURRAY Defendant CIVIL ACTION - DIVORCE/CUSTODY COMPLAINT IN DIVORCE Count I - Divorce 1. Plaintiff is Susan J. Murray, who currently resides at 3511 Country Side Lane, Camp Hill, Cumberland County, Pennsylvania since 1989. 2. Defendant is Peter D. Murray, who currently resides at 3511 Country Side Lane, Camp Hill, Cumberland County, Pennsylvania since 1989. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The parties were married on October 8, 1983 at Harrisburg, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The grounds for divorce are: a. the marriage is irretrievably broken. - ~~o..,.",.,,_ "" J ,..J' .,~il, " ~", -- .,,111II _ ^ ~'-",'."i,", ',,- .__, ""-' b. Defendant has committed adultery. c. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 7. Neither party is a member of the Armed Services of the United States of America. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have may have the right to request that the court require the parties to participate in counseling. Wherefore, Plaintiff requests the Court to enter a Decree in Divorce under sections 3301(c) and 3301(a)(2) and (a)(6) of the Divorce Code. Count II - Equitable Distribution 9. Plaintiff incorporates by reference paragraphs 1 through 8 above. 10. During the marriage, Plaintiff and Defendant have acquired various items of real and personal property. Wherefore, Plaintiff requests the Court to enter an Order equitably dividing all the marital property. Count III - Alimony 11. Paragraphs 1 through 8 are incorporated by reference. 12. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to support herself fully through appropriate employment. 13. Defendant has sufficient assets to provide continuing support for Plaintiff. Wherefore, Plaintiff requests the Court to enter an order granting her alimony. 2 - .,'~~" ,"A~'~~= j',. - ,n_ " '" ""'" ,;I~,I.'" J, ';"'-'-"......i!I.ill:o..~.t: Count IV - Alimony Pendente Lite, Counsel Fees and Expenses 14. Paragraphs 1 through 8 are incorporated by reference. 15. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to support herself fully through appropriate employment. 16. Defendant has sufficient assets to provide continuing support for Plaintiff. 17. Plaintiff has retained counsel to pursue this action and has agreed to pay her attorney a reasonable fee. 18. Plaintifflacks sufficient funds to meet the costs and expenses of pursuing this action, including counsel fees and the costs to retain experts to value the marital assets. 19. Defendant has sufficient assets to provide alimony pendente lite, counsel fees, costs and expenses for Plaintiff. Wherefore, Plaintiff requests the Court to enter an order awarding Plaintiff alimony pendente lite, interim counsel fees and expenses; and thereafter awarding Plaintiff such additional alimony, counsel fees and expenses as the Court deems just and appropriate. Count V - Custody 20. Plaintiff incorporates by reference the averments set forth in paragraphs 1 and 2. 21. Plaintiff seeks custody of the following child: Name Present Residence Date of Birth Brandon Murray 3511 Country Side Lane Camp Hill, PA 11/24/84 The child was not born out of wedlock. 3 " ~ ~ ~. The child presently is in the custody of Plaintiff, who resides at 3511 Country Side Lane, Camp Hill, PA. During the past five (5) years, the child has resided with the following persons at the following addresses: Name Address Dates Susan & Peter Murray 3511 Country Side Lane Camp Hill, PA 1988 to date The mother of the child is Plaintiff, currently residing at 3511 Country Side Lane, Camp Hill, PA. She is married. The father of the child is Defendant. He is married. 22. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Name Relationship Defendant Brandon Husband son 23. The relationship of defendant to the child is that of father. Defendant currently resides with the following persons: Name Relationship Plaintiff Brandon Wife son 4 ~ . ~, ,- d,. " " ,~- h ~ '-J" "LJ"" f< _ -' ~' ~ -,' ~\ _"-"1' 24. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or in another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 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 visitation rights with respect to the child. 25. The best interest and permanent welfare of the child will be served by granting the relief requested because Plaintiff is Brandon's primary caretaker. 26. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the children have been named as parties to this action. Wherefore, plaintiff requests the court grant custody of the child. ~~ Theresa Barrett Male, Esquire Supreme Court #46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Plaintiff Date: tf f 5 - , . "-I:...J<' ,,- ,W:"~l",,.6 ;;"', "' ~ ~ VERIFICATION I, Susan J. Murray, state upon personal knowledge or information and belief that the averments set forth in the foregoing document are true. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Itt:/'< JLj ~ ( l/1lLtlL~ Susan . Murray , Date: ~ / rzlb I - ,-~ ",0 .. Theresa Barrett Male Supreme Court #46439 513 North Second Street Harrisburg, PA 17101 (717) 233.3220 Counsel For Plaintiff ,> u , ......."""",'.,' " COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN J. MURRAY Plaintiff v. PETER D. MURRAY Defendant 01-3836 Civil Term CIVIL ACTION - DIVORCE/CUSTODY ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. Date: June 30 clv ,2001 i., ~~~~";"i"ili"'b'i]l~~~"'-'''''''''--ij{.b"n''fl_I~_ffi~~~~jf'''''~' 1'01;.,,11 L JI11:UtUl!1fl! n $UtUl _ ,'~ "~,,', " ",~,:;:," ,J~.~. , '~,' n'",'" O,M ,''', ,'., "~ ~, i:li!' ,~ ",0'<", ,"',U,",,','_~, l1'-"YO ~""""" ~ , .n _I '1 (j ~ ~, '-,' , ;:::. t'- I~' <"~, "-.....> C.:) ~.. ., ~ - I ;J,- ~'" i'_ ,. ";\ SUSAN J. MURRAY, : plaintiff : : vs. . . : PETER D. MURRAY, . . Defendant . . AUG 0 6 200~i\ IN THE OOURT OF CDMMON PLEAS OF 0 CUMBERLAND OOUNTY, PENNSYLVANIA 01-3836 CIVIL AcrION LAW In CUSTODY CIIDER. OF COORT AND NeW, this 1st day of August, 2001, the Conciliator, being advised by Plaintiff's counsel that Plaintiff withdraws her request for a Conciliation Conference at this time, hereby relinquishes jurisdiction in this case. FOR THE OOURT, ~ Custody Conciliator ~ ^-~"'~ " ~:;J~~~~_~!i3!~~;~.I<*~;lt'd;'i.;"i;,:'>:"t"'~',l"F';"'-':l'';w.!;i[,"'ii!;''l~'Ji,,,~~.\,'ji M.l.&.-"-"~"'II' .,~~]~ r _<>i,~, Q c :.0;: "'00:; m"', :z.~' :z.C <Q~. ~O ~O ?-C =Pc ~ ~!I.ll,IlH r' H .I ~ "~- ~...,.o,',"~, __" ,~ ~,' ~,'-""'~~_ ~, ,~,", ",'~. ",~",_, o :po - - ""' - C...:-, o -n :0;>' :;ll; o .' '-,G:j ,c) -, , --?:) _ -' ""{, --;,":,". :r.~ ~\?, 'j::; :< l'" c.'" .