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HomeMy WebLinkAbout07-1675TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 Telephone: (717) 731-8114 Facsimile: (717) 731-8115 RANDY KEITH HARRISON, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. Q'7 ?- LISA MARIE HARRISON, § CIVIL ACTION - DIVORCE/CUSTODY Defendant § 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 will proceed without you and a decree in divorce or annulment may 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, 4ncluding custody or visitation of your children: x 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 One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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,14ELP- CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 Bedford Street Carlisle, PA, 17013 (717) 249-3166 TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 Telephone: (717) 731-8114 Facsimile: (717) 731-8115 RANDY KEITH HARRISON, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. CV DV LISA MARIE HARRISON, § CIVIL ACTION- DIVORCE/CUSTODY Defendant § AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quesjas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se la avisa que si no defiende, el caso puede proceder sin usted y decreto de divorcio o anulmiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja o compensacion reclamadgs por-el demandante. Usted puede perder dinero, o propiedades u otros derechos importantas para usted. Cuando la base para el divorcio es indign Jades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary; yen One Courthouse Square, Carlisle; Pennsylvania. SI USTED NO RELAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE OR NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASI`STENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 Bedford Street Carlisle, PA 1701`3 (717)249=3166 TANNER LAW OFFICES, LLC 1300 Market Street, Suite. 10 Lemoyne, PA 17043 Telephone: (717) 731-8114 Facsimile: (717) 731-8115 RANDY KEITH HARRISON, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. r § NO. § "-7? LISA MARIE HARRISON, § CIVIL ACTION - DIVORCE/CUSTODY Defendant § COMPLAINT UNDER SECTION 3301(c) OR 3301 d OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Randy Keith Harrison, by and through his attorney, Tanner Law Offices, LLC, and represents as follows 1. Plaintiff is Randy Keith Harrison, an adult individual currently residing at 1911 Clarendon Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Lisa Marie Harrison, an adult individual currently residing at 155 Salem Church Road, Lot 61, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 21, 2001 in Cumberland County, Pennsylvania. 5. The marriage is irretrievably broken: Plaintiff and Defendant have lived separate and apart since November 1, 2006, and continue to live separate and apart as of the date of filing this Complaint. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety (90) days from the date of the filing of this Complaint, consent to this divorce. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 8. The Plaintiff has been advised ofthe availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 9. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiffprays that a decree in divorce be entered divorcing Plaintiff from the bonds of matrimony between the said Plaintiff and Defendant. COUNT I - CUSTODY 10. Paragraphs 1 through 9 are incorporated herein by reference as if set forth in their full text. i 11. Plaintiff seeks partial custody of the following children: Name Present Address Age Hunter Harrison 155 Salem Church Rd., Lot 61 Mechanicsburg, PA 17050 3 (D.O.B.11/1/2003) Jennifer Harrison 155 Salem Church Rd., Lot 61 8 Mechanicsburg, PA 17050 (D.O.B 11/20/1998) 12. Hunter Harrison was born in wedlock. Jennifer Harrison was born out of wedlock. 13. The children are presently in the custody of the Defendant, Lisa Marie Harrison, who resides at 155 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 14. During the last five years, the children have resided with the following persons at the following addresses: Persons : Address: Dates: Defendant 155 Salem Church Rd., Lot 61 Jennifer; (Defendant's girlfriend)New Cu b rl 11/1/2006 - Present m e and, PA 17970 , Plaintiff l efe danE `'` 155 Salem.Church Rd., Lot 61 New Cumbedarid,Pk17010 2/2004-11/1/2006 Plaintiff ' : Defendant Linden Court ; ? •: 1 1/ 2004 - 2/2004 Mechanicsburg, PA 17055 Donald Estright 405 Shelley Lane 12/2003 - 1/2004 Robin Estright Mechanicsburg, PA 17055 ScotHammaker Nicole Hammaker Plaintiff Defendant Plaintiff Twiggs Mobile Hotae 9/2000 - 12/2003 Defendant Mechanicsburg, pA,17055 15. The mother of the children is Defendant, Lisa Marie Harrison, currently residing at 155 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 16. The father of the children is Plaintiff, Randy Keith Harrison, currently residing at 1911 Clarendon Street, Camp Hill, Cumberland County, Pennsylvania 17011. 17. The relationship of the Plaintiff to the children is that of father. 18. The relationship of the Defendant to the children is that of mother. 19. Plaintiff has not participated as a party in other litigation concerning the custody of the child in a court of this Commonwealth or any other state. 20. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. 21. 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. 22. The best interests and permanent welfare of the child will be served by granting the relief requested. The quality of the child's- physical, intellectual, moral and spiritual environment would be improved by Plaintiff S continued interaction °in his children's lives. WHEREFORE, Plaintiff requests the Court to grant Partial Custody of the Child. Respectfully submitted, By: Tabetha A. Tanner, Esquire Suprem'e:Court I.D. No:: 91979 Attorney for Plaintiff TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements made herein may subject me to penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. . -(Q& -c)7 Date Ra Keit Harrison, Plaintiff ni Or p; RANDY KEITH HARRISON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LISA MARIE HARRISON DEFENDANT 07-1675 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, _ Monday, April 02, 2007 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at _ 4th Floor, Cumberland Coun Courthouse, Carlisle on Tuesday, April 24, 2007 at 10:30 AM 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: /s/ ac ueline M. Verne Es . 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Nno C O :OI W C- IJJV IQCZ Auvj:cli ":)j ]?u Jo 04 RANDY KEITH HARRISON: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-1675 CIVIL ACTION - LAW LISA MARIE HARRISON :IN CUSTODY Defendant PRAECIPE FOR ENTRY OF APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Lisa Marie Harrison, in the above captioned case. Respectf 1 y mitted, Je sica Holst, Esquire MidPenn Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 Date: y' / T . U ? RANDY KEITH HARRISON: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-1675 CIVIL ACTION - LAW LISA MARIE HARRISON :IN CUSTODY Defendant CERTIFICATE OF SERVICE I, Jessica Holst, Esquire, of MidPenn Legal Services, attorney for the Defendant, Lisa Marie Harrison, hereby certify that I have served a copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following date and in the manner indicated below: U.S. First Class Mail, Postage Pre-Paid Tabetha A. Tanner, Esquire 1300 Market Street - Suite 10 Lemoyne, PA 17043 Date: ?' I -4 - u- 4iddPe Hols t, Esquire nn n Legal Services 401 E. Louther Street Carlisle, PA 17013 (717) 243-9400 r, ?,,, n -.a {, :?, ? ?, ?=, , ?. r;? '. i _.... ,, ? r. R `' f ?7 G` ; ' ?? APR 87 2001 A RANDY KEITH HARRISON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-1675 CIVIL ACTION - LAW LISA MARIE HARRISON, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 3a tb day of , 2007, upon consideration of the attached Custody Conciliation Re ort, it is ordered and directed as follows: 1. The Father, Randy Keith Harrison and the Mother, Lisa Marie Harrison, shall have shared legal custody of Hunter Harrison, born November 1, 2003 and Jennifer Harrison, born November 20, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to medical, dental, religious or school records, the residence address of the children and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to- school nights, and the like. 2. Mother shall have primary physical custody of the children. 3. Father shall have the following periods of partial physical custody: A. Four (4) consecutive weekends beginning Saturday, April 28, 2007 from Saturday at 10:00 a.m. to Sunday at 12:00 noon. Custody exchanges shall occur at the Lowe's in Carlisle. B. Thereafter, beginning June 1, 2007, alternating weekends from Friday after school and daycare to Sunday at 12:00 noon. In the event there is no school on Friday or Monday and Father is off from work, his v ?Y t i `-.} Tf ?J v ITV Jt, ti f :Z Rd I - W LOOZ At vioiN sH-[,, ,l d 3Hl J -O custodial period shall include Thursday and/or Monday. Father shall pick up the children at school and daycare to begin his period of custody and the parties shall meet at the Giant in Camp Hill on Sunday to exchange custody. 4. Both parties are entitled to 2 non-consecutive weeks of custody during the year provided they give the other parry 30 days prior notice and a location and telephone number where the children may be reached. 5. Holidays: A. Thanksgiving shall be shared and alternated. Father shall have custody of the children in odd numbered years from 9:00 a.m. to 3:00 p.m. and in even numbered years from 3:00 p.m. to 9:00 p.m. Mother shall have custody of the children from 9:00 a.m. to 3:00 p.m. in even numbered years and 3:00 p.m. to 9:00 p.m. in odd numbered years. B. Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. C. Easter shall be shared such that Father shall always have the children from 9:00 a.m. to 3:00 p.m. and Mother shall always have the children from 3:00 p.m. to 9:00 p.m. 6. The parties shall have liberal telephone contact with the children. 7. The parties are prohibited from discussing custody issues in front of the children and shall prevent third parties from discussing custody issues in front of the children. The children shall not be used to carry messages regarding custody between the parents. 8. Neither party shall do or say anything nor permit a third party from doing or saying anything that may estrange the children from the other parent, injure the opinion of the children as to the other parent, or hamper the free and natural development of the children's love and respect for the other parent. 9. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, /" 02 J. cc: Tabetha A. Tanner, Esquire, Counsel for Father /-a Jessica Holst, Esquire, Mid Penn Legal Services, Counsel for Mother RANDY KEITH HARRISON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-1675 CIVIL ACTION - LAW LISA MARIE HARRISON, Defendant : IN CUSTODY PRIOR JUDGE: J. Wesley Oler, Jr., J. CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Hunter Harrison November 1, 2003 Mother Jennifer Harrison November 20, 1998 Mother 2. A Conciliation Conference was held in this matter on April 26, 2007, with the following in attendance: The Father, Randy Keith Harrison, with his counsel, Tabetha A. Tanner, Esquire, and the Mother, Lisa Marie Harrison, with her counsel, Jessica Holst, Esquire, Mid Penn Legal Services. 3. A PFA Order of Court was entered by the Honorable J. Wesley Oler, Jr. dated December 13, 2006. It did not contain any custody provisions. 4. The parties agreed to an Order in the form as attached. Date -Jac eline M. Verney, Esquire Custody Conciliator Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 ttanner@tanner-law.com RANDY KEITH HARRISON, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA § V. § NO. 2007-1675 LISA MARIE HARRISON, § CIVIL ACTION -DIVORCE Defendant § AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 27, 2007. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) 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 Divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: 2-17 r Harrison, Plaintiff C-M C c -r7 - re-, Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 taanner@tanner-law.com RANDY KEITH HARRISON, § Plaintiff § V. § LISA MARIE HARRISON, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-1675 CIVIL ACTION - 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 made herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: -7-1? - O ? - andy ith Harrison, Plaintiff 1W - ?? ? ( 4 . r ""F"'S F ,.°,. "" ??=' '? ..( RANDY KEITH HARRISON, § Plaintiff § V. § LISA MARIE HARRISON, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-1675 CIVIL ACTION - DIVORCE/CUSTODY EMERGENCY PETITION FOR MODIFICATION OF PARTIAL CUSTODY OR VISITATION ORDER PURSUANT TO 23 Pa.C.S. 5310 TO PREVENT ENDANGERMENT AND NOW, comes the Petitioner, Randy Keith Harrison, by his attorney, Tanner Law Offices, LLC, and represents as follows: 1. Petitioner, Randy Keith Harrison, is an individual currently residing at 1911 Clarendon Street, Camp Hill, Cumberland County, Pennsylvania 1701 L 2. Respondent, Lisa Marie Harrison, is an adult who does not have a stable address. 3. Petitioner respectfully represents that on April 30, 2007, an Order of Court was entered for Custody based on a April 26, 2007 Custody Conciliation Conference. 4. The children do not have a stable environment in which to reside, are at times residing at places without electricity or food; are being taught and encouraged to be disrespectful by photographing the three (3) year old sticking up his middle finger for the camera; and are being hit by the Respondent's girlfriend. 5. Respondent has been staying with her aunt, Bonnie. Aunt Bonnie resides in a 2 bedroom trailer with her husband and son. Respondent and the parties' children have been sleeping on the floor. 6. Respondent has been staying with her girlfriend, Jo's, mother. Jo's mother is an alcoholic and does not provide a safe environment for the children. 7. Petitioner believes, and therefore avers that the children are currently staying at a residence without electricity or food. 8. Respondent's girlfriend, Jo, is physically abusive to both Hunter and Jennifer. 9. Respondent's girlfriend, Jo, called Petitioner at work and told him that she was going to kill him, but was just waiting for the right moment. 10. The, parties' three (3) year old son, Hunter, has been taught and encouraged to disrespect others by sticking up his middle finger for the camera (Exhibit "A") 11. Respondent's girlfriend, Jo, who is holding Hunter in Exhibit "A" is a bad influence on the children. 12. Respondent has shown an inability to make good decisions and make good judgments as it pertains to the parties' children. 13. They parties' daughter, Jennifer Harrison, born November 20, 1998 has been diagnosed with ADD. As a result, she has been prescribed medication which she must take on a daily basis. 13. During Petitioner's periods of partial custody, Respondent has not provided Petitioner with Jennifer's medication. 14. Petitioner believes that Respondent is not providing Jennifer with the proper dosage of her prescribed medications. 15. Asa result of Respondent's failure to give Jennifer her medication or to provide Petitioner with the medication, Jennifer is agitated and at times unmanageable. 16. The April 30, 2007 Order was entered by the Honorable Judge Oler. 17. Respondent is unrepresented and has not been contacted to determine her concurrence with this Petition. WHEREFORE, Petitioner requests that the Court modify the existing order for Custody to provide Father with primary physical custody of the Children. Respectfully submitted, Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 Attorney for Petitioner/Plaintiff TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements made herein may subject me to penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: -7-/&--03- RANDY KEITH HARRISON, § Plaintiff § V. § LISA MARIE HARRISON, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-1675 CIVIL ACTION - DIVORCE/CUSTODY CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I served a copy of the Petition, filed in the above- captioned matter, upon Jessica Holst, Esquire via regular first class mail, postage prepaid, and first class mail, certified, restricted delivery, return receipt requested , addressed as follows: Date: _?o 6 Ms. Lisa Marie Harrison 90 Salem Church Road Lot 404 Mechanicsburg, PA 17050 Respectfully submitted, .. 7???& 4 -lanow Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 Attorney for Plaintiff TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 -- ? ? c. ?_ ?? RY f '. 1 i? ?' ` ' G"3 _ i 4 ^p w6 .:c? a. "z? G J :-? ?.E ..` RANDY KEITH HARRISON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LISA MARIE HARRISON, Defendant NO. 07-1675 CIVIL TERM IN RE: PLAINTIFF'S EMERGENCY PETITION FOR MODIFICATION OF PARTIAL CUSTODY OR VISITATION ORDER PURSUANT TO 23 Pa. C.S. §5310 TO PREVENT ENDANGERMENT ORDER OF COURT AND NOW, this 27th day of July, 2007, upon consideration of Plaintiff's Emergency Petition for Modification of Partial Custody or Visitation Order Pursuant to 23 Pa. C.S. §5310 To Prevent Endangerment, the matters raised in the present petition are hereby referred to the custody conciliation process and the Court Administrator is directed to facilitate this referral. abetha A. Tanner, Esq. 1300 Market Street Suite 10 Lemoyne, PA 17043 Attorney for Plaintiff a Marie Harrison 90 Salem Church Road Lot 404 Mechanicsburg, PA 17050 Defendant, pro Se BY THE COURT, J Court Administrator--- I'jh4w-d :rc AtNCA- W ZQ T kd L Z 717r LOOT AWjaVQHIQ'dd 3-a d0 30[+Z Ceg RANDY KEITH HARRISON IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LISA MARIE HARRISON DEFENDANT 07-1675 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 01, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. the conciliator, at4th Floor, Cumberland County Courthouse, Carlisle on Thursday, August 23, 2007 at 8:30 AM 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 pennanent 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: /s/ ac uelrne M. Verne Es q. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 4J LS •01 WV C- OAV LOOZ AdvioNllilurl",-ld :,,Hi do 3^i??'?l?lld I . RANDY KEITH HARRISON, § Plaintiff § V. § LISA MARIE HARRNON, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-1675 CIVIL ACTION - CUSTODY STIPULATED CUSTODY AGREEMENT AND NOW, this day of Auaj_st , 2007, Randy Keith Harrison, residing at 1911 Clarendon Street, Camp Hill, Cumberland County, Pennsylvania 17011 (hereinafter referred to as "Father"), Lisa Marie Harrison, residing at 931 South 21St Street, Camp Hill, Cumberland County, Pennsylvania 17011 (hereinafter referred to as "Mother") (Mother and Father are individually "Parent" and collectively "Parents") and Robin Estright residing at 405' Sheely Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 (hereinafter referred to as the Legal Guardian) hereby stipulate and agree to the following regarding custody of their minor children, Hunter Harrison, born November 1, 2003, and Jennifer Harrison, born November 20, 1998. A. Legal Custody. The parties and the legal guardian shall have shared legal custody of the Children. Each Parent and Robin Estright shall have an equal right, to be exercised jointly with the other Parent, to make all non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa.C.S. §5309, each Parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the a . residence-address for the Children and of the other Parent. To the extent one Parent has possession of any such records or information, that Parent shall be required to share the same, or copies thereof, with the other parent, within such reasonable time as to make the records and information of reasonable use to the other Parent. In addition to the foregoing, the following shall also apply to the parties' legal custody rights and" obligations: 1. Drugs and Alcohol: During any period of custody or visitation, neither Parent nor the legal guardian shall possess or use any controlled substance, or consume alcoholic beverages to the point of intoxication, nor permit any other household members and guests or other persons to possess or use any controlled substance or consume alcoholic beverages to the point of intoxication in the presence of the Children. 2. No Derogatory Comments: Neither Parent nor the legal guardian shall undertake, or permit by any other person, the poisoning of the Children's minds against the other Parent, by conversation or otherwise, any communication that explicitly or implicitly degrades, ridicules, condemns, or in any other way attempts to alienate the affections of the Children toward the other Parent. At all times, each Parent shall encourage and foster in the Children a sincere affection for the other Parent. 3. Telephone Contact: Both Parents shall be afforded reasonable telephone contact with the Children while in the other Parent's or the legal guardian custody and for said purposes each Parent shall provide the other Parent with his or her home telephone number. Said reasonable telephone contact with the children shall be at 7PM unless otherwise agreed by the parties. Said telephone B. Physical Custody: 1. Primary Custody: Robin Estright shall exercise primary physical custody of the children, subject to the custody schedule as set forth herein. 2. Partial Custody: Mother and Father shall have the rights of partial custody of the Children, subject to the custody schedule as set forth herein. 3. Custody Schedule: a. Father shall exercise custody of the Children every other weekend commencing with the weekend of August 10, 2007 from Friday after work until Sunday at 12:00 noon. In the event that there is no school on Friday or Monday and Father is off from work, his custodial period shall include the Thursday and/or Monday. b. Mother shall exercise custody of the Children every other weekend commencing with the weekend of August 3, 2007 from Friday after work until Sunday at 6:00 p.m.. In the event that there is no school on Friday or Monday and Mother is off from work, his custodial period shall include the Thursday and/or Monday. 4. Vacation Schedule: Each Parent shall be entitled to two (2) uninterrupted weeks of vacation time with the Children per year. Each Parent shall provide the other Parent with thirty (30) days notice of his or her intention to exercise this period of physical custody. a. Conflict: Should a conflict arise between the selection of said week the first Parent to notify the other Parent of his or her selection shall have the right to exercise physical custody on the week selected and the other Parent shall select other times for his or her week so as to avoid any conflicts. b. Flexibility: The parties shall be flexible and cooperate with each other to adjust their vacation schedules as may be necessary to accommodate special vacation plans, rental requirements, and the like. 5. Ho`lidavs: a. Easter: Father shall exercise custody of the Children on every Easter from 9AM until 3PM. Mother shall exercise custody of the Children every Easter from 3PM until 9PM b. Thanksgiving Day: During the odd numbered years, commencing with 2007, Father shall have custody of the Children from 9AM until 3 PM. Mother shall have custody of the Children from 3PM until 9PM. During the even numbered years, commencing with 2008, Mother shall have custody of the Children from 9AM until 3PM. Father shall have custody of the Children from 3PM until 9PM. C. Christmas Day: Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from Christmas Day at 12:00 noon to December 26" at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 6. Special Days: a. Father's Day: Father shall exercise custody of the Children on Father's Day. b. Mother's Day: Mother shall exercise custody of the Children on Mother's Day. 7. Precedence: The holiday and Special Days schedule shall take precedence over any other custodial period set forth herein. 8. Transportation: Transportation to effectuate any periods of custody shall be as follows: a. The parties shall pick up and drop off from Robin Estright's home, located at 405 Sheely Lane, Mechanicsburg, PA 17050. 9. Relocation: Neither party may relocate outside of a fifty (50) mile radius from their current residence without permission from the other party or a court order granting said relocation. 10. Medication: Both parties and Robin Estright shall ensure that the parties' daughter, Jennifer, receive the full dosage of medication as prescribed by her physician for treatment of her ADD. The legal guardian shall ensure that the prescriptions are timely filled and that Jennifer is provided with the medication on a daily basis or as further prescribed by her physician. 11. Custody Issues: The parties are prohibited from discussing custody issues in front of the Children, and shall prevent third parties from discussing custody issues in front of the Children. The Children shall not be used to carry messages regarding custody between the Parents. 12. Waiver of Custody: A waiver of any period of custody during any year shall not be construed as a waiver of any future period of custody. 13. Modification: The Parents shall be at liberty to modify the physical custody schedule as indicated herein to accommodate their respective schedules and special occasions, subject to the mutual agreement of both Parents. If such modification is in writing (including email) which evidences the mutual agreement of the Parents, it shall be binding upon the parties to the extent and for:the duration which was mutually agreed upon by the Parents. No Parent shall be deemed to be in contempt of court for abiding by the terms of any such written mutual agreement. C. Entry of Court Order: The parties authorize the Court of Common Pleas of Cumberland County, Pennsylvania to enter an order incorporating the terms of this I, Stipulated Custody Agreement. IN WITNESS WHEREOF, the Parents, intending to be legally bound hereby, have set their hands and seals the day and year written below. Witness: %&Z??L A -Ialln? 4. -IqI7? . 4 an eith Harrison, Father Robin Estright, Legal Guardian Date: ?i I - o r. -T, 7 C %f • r RANDY KEITH HARRISON, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 2007- 1675 LISA MARIE HARRISON, § CIVIL ACTION - IN CUSTODY Defendant § STIPULATED ORDER FOR CUSTODY AND NOW, this T day of , 2007, this Order is being entered as a result of an Agreement reached between the parties as evidenced by the attached Stipulated Custody Agreement, dated August 1, 2007. The matter is before the Court on Plaintiff's Complaint. This matter involves the custody of: Jennifer Harrison Date of Birth: 11/20/1998 Age: 8 Hunter Harrison Date of Birth: 11/1/2003 Age: 3 A previous Court Order was entered by the Honorable Judge Oler on April 30, 2007. A. Legal Custody: The parties and the legal guardian shall have shared legal custody of the Children. Each Parent and Robin Estright shall have an equal right, to be exercised jointly with the other Parent, to make all non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of Pa.C.S. §5309, each Parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, Page 1 of 7 LU c, cr-t LtJ . zz? `{ Q cm ° v r.A t religious or school records, the residence address for the Children and of the other Parent. To the extent one Parent has possession of any such records or information, that Parent shall be required to share the same, or copies thereof, with the other parent, within such reasonable time as to make the records and information of reasonable use to the other Parent. In addition to the foregoing, the following shall also apply to the parties' legal custody rights and obligations: 1. Drugs and Alcohol: During any period of custody or visitation, neither Parent nor the legal guardian shall possess or use any controlled substance, or consume alcoholic beverages to the point of intoxication, nor permit any other household members and guests or other persons to possess or use any controlled substance or consume alcoholic beverages to the point of intoxication in the presence of the Children. 2. No Derogatory Comments: Neither Parent nor the legal guardian shall undertake, or permit by any other person, the poisoning of the Children's minds against the other Parent, by conversation or otherwise, any communication that explicitly or implicitly degrades, ridicules, condemns, or in any other way attempts to alienate the affections of the Children toward the other Parent. At all times, each Parent shall encourage and foster in the Children a sincere affection for the other Parent. 3. Telephone Contact: Both Parents shall be afforded reasonable telephone contact with the Children while in the other Parent's or the legal guardian custody and for said Page 2 of 7 purposes each Parent shall provide the other Parent with his or her home telephone number. Said reasonable telephone contact with the children shall be at 7PM unless otherwise agreed by the parties. Said telephone B. Physical Custody: 1. Primary Custody: Robin Estright shall exercise primary physical custody of the children, subject to the custody schedule as set forth herein. 2. Partial Custody: Mother and Father shall have the rights of partial custody of the Children, subject to the custody schedule as set forth herein. 3. Custody Schedule: a. Father shall exercise custody of the Children every other weekend commencing with the weekend of August 10, 2007 from Friday after work until Sunday at 12:00 noon. In the event that there is no school on Friday or Monday and Father is off from work, his custodial period shall include the Thursday and/or Monday. b. Mother shall exercise custody of the Children every other weekend commencing with the weekend of August 3, 2007 from Friday after work until Sunday at 6:00 p.m.. In the event that there is no school on Friday or Monday and Mother is off from work, his custodial period shall include the Thursday and/or Monday. Page 3 of 7 4. Vacation Schedule: Each Parent shall be entitled to two (2) uninterrupted weeks of vacation time with the Children per year. Each Parent shall provide the other Parent with thirty (30) days notice of his or her intention to exercise this period of physical custody. a. Conflict: Should a conflict arise between the selection of said week the first Parent to notify the other Parent of his or her selection shall have the right to exercise physical custody on the week selected and the other Parent shall select other times for his or her week so as to avoid any conflicts. b. :Flexibility: The parties shall be flexible and cooperate with each other to adjust their vacation schedules as may be necessary to accommodate special vacation plans, rental requirements, and the like. 5. Holidays: a. Easter: Father shall exercise custody of the Children on every Easter from 9AM until 3PM. Mother shall exercise custody of the Children every Easter from 3PM until 9PM b. Thanksgiving Day: During the odd numbered years, commencing with 2007, Father shall have custody of the Children from 9AM until 3 PM. Mother shall have custody of the Children from 3PM until 9PM. During the even numbered Page 4 of 7 years, commencing with 2008, Mother shall have custody of the Children from 9AM until 3PM. Father shall have custody of the Children from 3PM until 9PM. C. Christmas Day: Christmas shall be divided into two Blocks. Block A shall be from 12:00 noon on Christmas Eve to 12:00 noon on Christmas Day. Block B shall be from Christmas Day at 12:00 noon to December 26th at 12:00 noon. Mother shall have Block A in odd numbered years and Block B in even numbered years. Father shall have Block A in even numbered years and Block B in odd numbered years. 6. Special Davs: a. Father's Day: Father shall exercise custody of the Children on Father's Day. b. Mother's Day: Mother shall exercise custody of the Children on Mother's Day. 7. Precedence: The holiday and Special Days schedule shall take precedence over any other custodial period set forth herein. 8. Transportation: Transportation to effectuate any periods of custody shall be as follows: a. The parties shall pick up and drop off from Robin Estright's home, located at 405 Sheely Lane, Mechanicsburg, PA 17050. Page 5 of 7 9. Relocation: Neither party may relocate outside of a fifty (50) mile radius from their current residence without permission from the other party or a court order granting said relocation. 10. Medication: Both parties and Robin Estright shall ensure that the parties' daughter, Jennifer, receive the full dosage of medication as prescribed by her physician for treatment of her ADD. The legal guardian shall ensure that the prescriptions are timely filled and that Jennifer is provided with the medication on a daily basis or as further prescribed by her physician. 11. Custody Issues: The parties are prohibited from discussing custody issues in front of the Children, and shall prevent third parties from discussing custody issues in front of the Children. The Children shall not be used to carry messages regarding custody between the Parents. 12. Waiver of Customs: A waiver of any period of custody during any year shall not be construed as a waiver of any future period of custody. 13. Modification: The Parents shall be at liberty to modify the physical custody schedule as indicated herein to accommodate their respective schedules and special occasions, subject to the mutual agreement of both Parents. If such modification is in writing (including email) which evidences the mutual agreement of the Parents, it shall be binding upon the parties to the extent and for the duration which was mutually agreed Page 6 of 7 upon by the Parents. No Parent shall be deemed to be in contempt of court for abiding by the terms of any such written mutual agreement. Page 7 of 7 BY THE COURT, AUG 2 0 ZOO r A'S RANDY KEITH HARRISON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-1675 CIVIL ACTION - LAW LISA MARIE HARRISON, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 20th day of August, 2007, the parties having reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, 1vl cquel e M. Verney, Esquire, Custody Co ator C Em . C) C3 r? u Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 ttanner@tanner-law.com RANDY KEITH HARRISON, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 2007-1675 LISA MARIE HARRISON, § CIVIL ACTION -DIVORCE Defendant § AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 27, 2007. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) 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 Divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: isa Marie Harrison, Defendant ['? c _? c`-' Y' ( { ?? ; ?. ?? ?'r ? _ -, , r .»? 0 Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 ttanner@tanner-law.com 0 RANDY KEITH HARRISON, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 2007-1675 LISA MARIE HARRISON, § CIVIL ACTION -DIVORCE Defendant § 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 I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to, authorities. Date: - f r 0`7 tsa Marie Harrison, Defendant ? t h.? ?? :.r.. ?'°., } a f'?... ?"?7 .5 + , ti r?,?3 .? ."'w. j . TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 Telephone: (717) 731-8114 Facsimile: (717) 731-8115 RANDY KEITH HARRISON, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA V. § NO. 2007-1675 LISA MARIE HARRISON, § CIVIL ACTION - DIVORCE Defendant § CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I served a copy of the Complaint in Divorce filed in the above-captioned matter upon the Defendant, Lisa Marie Harrison, by regular and certified mail, restricted delivery, return receipt requested, addressed as follows: Ms. Lisa Marie Harrison 155 Salem Church Rd., Lot 61 Mechanicsburg, PA 17050 and did thereafter receive same as evidenced by the attached Post Office receipt card dated April 5, 2007. Respectfully submitted, 7/0" 4, lmeLl?' Tabetha A. Tanner, Esquire Supreme Court I.D. No.: 91979 4 . . r-1 (Domestic Mail Only,- N vided o Insurance Coverage Pfc tr cc ' rAL US- ..n Ir Postage $ In d F ifi ?•{ ``?+ ?? r9 ee Cert e Poelr4rk C3 O Return Receipt Fee (Endorsement Required) Ej . $5i ?' . UUT C3 Restricted Delivery Fee (Endorsement Required) 93+7?t O & Fees l P t y #$ " age os Tota SOVI? M o to ?5 Lisa .. ...- f jC .-• - x.?. Scar........_.?._.. _ POBoxNo j T- S C ?? V . or Q ._.. . tt __ 1ltt. 00"108b MbN ? 1. z$ MW a. Iwo 1, Mm 4 If R Md D*MSrY is d?ind. is FOft YW nrt» aid •ddnss at the I IN W W" so #td we ciwn ttbtm Vw card to You. a Att ch this osrd to #w book of 1M ffwMPW ^ __ -.&- &-.A at .noes nmvt ts. 1. Md• Addpeewd to: hjTch X55 Sa 1 Ov cp L Qr- IWSV 4(6 Cs?1U lnccwrolf WMWWW z. sonta•wo•11tD 7©g6?3450 ggql 8966 8991 IK Mu "1. l00tt ct?"tww ts? tilo.ielt l4 O bM O No R RE4 ;n r,a D : -- t : ? ca r . 0% Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 ttanner@tanner-law.com RANDY KEITH HARRISON, § Plaintiff § V. § LISA MARIE HARRISON, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-1675 CIVIL ACTION - DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of Service of the Complaint: United States Postal Service, first class mail, postage prepaid, certified, restricted delivery. Return receipt dated April 5, 2007. 3. Date of Execution of the Affidavit of Consent Required by Section 3301(c) of the Divorce Code: by Plaintiff on July 19, 2007; by Defendant on August 24, 2007. 4. Related Claims Pending: no other marital claims pending. 5. Date of Filing Waivers of Notice: Plaintiff's waiver was filed on July 19, 2007; Defendant's waiver was filed on August 24, 2007. ,, . r? ?/1_lan Tabetha A. Tanner, Esquire Attorney for Plaintiff Supreme Court I.D. No. 91979 TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 731-8114 TAT/mrp r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. f(p 7-s N O . gnn7-4 r7 Plaintiff VERSUS Defendant DECREE IN DIVORCE AND NOW, ZZ Z00 , IT IS ORDERED AND DECREED THAT Randy Lj{„eith Hatesir-Qn , PLAINTIFF, AND T,i-qa Marie Harriann DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; BY THE COU PROTHONOTARY , -.r,e _L gyp. ec-l-