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HomeMy WebLinkAbout07-6582BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff MELISSA K. CARRION, Plaintiff V. JAIME A. CARRION, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- b58a om I Tc'm : CIVIL ACTION -LAW : IN DIVORCE AND CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Cumberland County Courthouse, 1 Courthouse Square, 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 1-800-990-9108 BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff MELISSA K. CARRION, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. JAIME A. CARRION, CIVIL ACTION -LAW Defendant IN DIVORCE AND CUSTODY AVISO PARA DEFENDER Y RECLAIMAR DERECHOS LISTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio o anulamiento puede ser emitado en su contra por la Corte. Una decision puede tambi6n ser emitida en su contra por caulquier otra queja o compensaction reclamados por el demandante. Usted puede perder dinero, o sus propiedades o otros derechos importantes para usted. Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales estA disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTACIA, 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 O NO PUEDO PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff MELISSA K. CARRION, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. JAIME A. CARRION, Defendant NO. o -7- GS J>Z Cz?-4 -74L.- CIVIL ACTION -LAW : IN DIVORCE AND CUSTODY COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(a)(6) OF THE DIVORCE CODE 1. Plaintiff is Melissa K. Carrion, an adult individual who currently resides at 4135 Wertzville Road, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Jaime A. Carrion, an adult individual who currently resides at 4135 Wertzville Road, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 19, 2002, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that there is one (1) child of this marriage under the age of eighteen years, namely Matthew Angel Carrion born on April 22, 2001. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 11. During the course of the marriage the Defendant has offered indignities to the Plaintiff, the innocent and injured spouse, so as to make Plaintiff's condition burdensome and life unbearable. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301(c) or 3301 (a) (6) of the Divorce Code. COUNT II CUSTODY 12. Paragraphs one (1) through eleven (11) of this Complaint are incorporated herein by reference. 13. Plaintiff is Melissa K. Carrion, an adult individual who currently resides at 4135 Wertzville Road, Enola, Cumberland County, Pennsylvania 17025. 14. Defendant is Jaime A. Carrion, an adult individual who currently resides at 4135 Wertzville Road, Enola, Cumberland County, Pennsylvania 17025. 15. Plaintiff Melissa K. Carrion seeks custody of the following child: Name Address Date of Birth Matthew Angel Carrion 4135 Wertzville Road April 22, 2001 16. The child was born in wedlock. The child is presently in the custody of Plaintiff, residing at 4135 Wertzville Road, Enola, Pennsylvania 17025. 17. During the past five (5) years, the child has resided with the following persons the following address(es): Name Address Dates Melissa K. Carrion-mother 4135 Wertzville Road 2001 to present Enola, Pa Jaime A. Carrion-father Juan Steward- brother 18. The father of the child is currently residing at 4135 Wertzville Road, Enola, Pennsylvania. Plaintiff is filing a Divorce Complaint and a Petition for Exclusive Possession simultaneously with this complaint. 19. The relationship of Plaintiff to the child is that of mother. Plaintiff currently resides with the following person(s); Name Relationship Self Jaime Carrion Husband Matthew Carrion Son Juan Steward Son 20. The relationship of Defendant to the child is that of father. Defendant is currently resides with the following person(s): Name Relationship Self Melissa Carrion Wife Juan Steward Son Matthew Carrion Son 21. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the child in this or any other Court. 22. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 23. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims too have custody or visitation rights with respect to the child. 24. The best interest and permanent welfare of the child will be served by granting the relief requested because: a. Defendant is an alcoholic and his behavior has recently deteriorated. He was arrested on September 2, 2007 for Simple Assault in Dauphin County and was arrested on September 19, 2007 for DUI in Cumberland County and fired on October 10, 2007 from LA Fitness for getting into an altercation with a customer; and b. Defendant is threatening to take the child to Puerto Rico to live with his relatives or take him to Brooklyn, New York to live with relatives to keep him from Plaintiff. 25. 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 the parties to this action. WHEREFORE, Plaintiff requests the Court to grant her custody of the minor child Matthew Angel Carrion. COUNT III EQUITABLE DISTRIBUTION 26. Paragraphs one (1) through twenty-five (25) of this Complaint are incorporated herein by reference. 27. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. 28. The parties have acquired marital debt during their marriage. 29. Plaintiff and Defendant may be unable to resolve amicably the property issues in this matter. WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all marital property and debt. Date: 3?0 - , - Respectfully submitted, JOANNE HARRISON CLOUGH, PC Joanne Harrison Clough, Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff VERIFICATION I, Melissa Carrion, hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn verification to authorities. DATE: Melissa Carrion .! { - = w r l ?r I ? i-n ka. 4 , JOANNE HARRISON CLOUGH, PC BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff MELISSA K. CARRION, Plaintiff V. JAIME A. CARRION, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. "e`°-- CIVIL ACTION -LAW IN DIVORCE AND CUSTODY PETITION FOR EMERGENCY RELIEF AND/OR MAINTAIN THE STATUS QUO UNTIL HEARING AND NOW, this 30th day of October, 2007, comes the Petitioner, Melissa K. Carrion, by and through their attorney, Joanne Harrison Clough, Esquire and files this Petition for Emergency Relief and in support thereof avers as follows: 1. Plaintiff Melissa K. Carrion is an adult individual who is currently residing at 4135 Wertzville Road, Enola, Cumberland County Pennsylvania, 17025. 2. Defendant Jaime A. Carrion is an adult individual residing at residing at 4135 Wertzville Road, Enola, Cumberland County Pennsylvania, 17025. 3. Plaintiff is filing a Divorce and Custody Complaint simultaneously with the filing of this Petition For Emergency Relief. 4. Plaintiff is the mother of the minor child Matthew Angel Carrion, born April 22, 2001. Defendant is the father of said child. 2 5. Defendant Jaime Carrion has one child from a previous marriage, Mykel Carrison, age 15, who resides with his mother in the state of New York. 6. Defendant has a long history of alcohol abuse and is an alcoholic who is currently drinking and his recent behavior is becoming increasingly out of control as follows: a. Defendant was arrested on September 2, 2007 for Simple Assault and Possession of a Prohibited Offensive Weapon in Dauphin County and is currently on bail for said charges; b. On September 19, 2007, Defendant was arrested for DUI in Camp Hill, Cumberland County, PA, and has charges pending against him. This is Defendant's fifth (5") DUI charge. c. On October 10, 2007, Defendant was fired from his job at LA Fitness for getting in to a confrontation with a customer; d. Defendant has been repeatedly drunk at home for the past several months and was very loud and out of control on the evening of October 29, 2007 and he physically disabled his son Juan's car so he could not drive to school and repeatedly threatened to take the parties' minor son Matthew to Puerto Rico;. e. Defendant continues to drink at home and then leaves the residence to drink and returns home severely intoxicated. 9. Defendant Jaime Carrion is an alcoholic and has a pattern of acting erratically when he is intoxicated. 10. Defendant has recently threatened Plaintiff that he is going to take the parties' son Matthew Angel Carrion and flee Pennsylvania and go to Puerto Rico or Brooklyn, New York, to keep the child from Plaintiff. 3 11. Plaintiff believes and therefore avers that Defendant knows that he will be sentenced to a prison term and Defendant is likely to flee the jurisdiction prior to trial. Defendant did flee to Puerto Rico in 1996 for two years, when he was on probation and had a DUI charge pending. 12. Matthew Angel Carrion is a six year old boy who is enrolled in first grade at Shaull Elementary School, in Cumberland Valley School District. 14. Plaintiff is seeking emergency relief from the court to place the child in her temporary care and physical custody until a hearing can be held. 15. The best interest and permanent welfare of the child Matthew Angel Carrion will be served by granting the relief requested and that minor child be placed in her physical custody until a hearing on the Petition for Emergency Relief can be held. WHEREFORE, Plaintiff Melissa K. Carrion requests the Court issue an Order directing the child Matthew Angel Carrion be placed in her physical custody pending a hearing on this Petition For Emergency Relief, and order that the child shall not be removed from Pennsylvania or from the school by the Defendant, and grant any further relief this Court deems appropriate. Date:' Respectfully submitted, JO H, PC Joanne klarrison Clougl Attorney ID No.: 3646 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff 4 VERIFICATION I, Melissa Carrion, hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn verification to authorities. DATE:' Melissa-Carrion JOANNE HARRISON CLOUGH, PC BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff MELISSA K. CARRION, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0,7-1,57k JAIME A. CARRION, CIVIL ACTION -LAW Defendant IN DIVORCE AND CUSTODY PLAINTIFF MELISSA K. CARRION'S PETITION FOR EXCLUSIVE POSSESSION OF MARITAL RESIDENCE AND NOW, this ?J)&"r_day of 2007, comes the Petitioner, Melissa K. Carrion by and through her attorney, Joanne Harrison Clough, Esquire, and files this Petition for Exclusive Possession of Marital Residence and in support thereof aver as follows: 1. Petitioner Melissa K. Carrion is represented by Joanne Harrison Clough, Esquire. 2. Respondent Jaime A. Carrion is not presently represented by counsel. 3. The parties currently reside at residence is located at 4135 Wertzville Road, Enola, Cumberland County, PA 17025. Said property is solely owned by Plaintiff Melissa K. Carrion and was purchased in July of 1999, three (3) years prior to the parties' marriage. 4. On or about October 30, 2007, Petitioner Melissa K. Carrion filed a Divorce and Custody Action against the Defendant/Respondent Jaime A. Carrion simultaneously with this filing of this Petition. 5. Respondent Jaime A. Carrion is an alcoholic who is currently drinking to excess constantly and his behavior is spiraling out of control as follows: a. He was arrested on September 2, 2007 for Simple Assault; b. He was arrested on September 19, 2007 for D.U.I.; c. He was fired on October 10, 2007 for getting into an altercation with a customer' d. He is constantly drunk at home and on October 29, 2007 he physically disabled the car of the parties 18 year old son to prevent him from driving to school. e. On October 29, 2007 Respondent was drunk and repeatedly threatened to remove the minor six year old child from the house and flee with him to Puerto Rico or Brooklyn, New York. 6. Respondent Jaime A. Carrion has made drunken and threatening statements to Petitioner stating "this is going to get ugly". 7. Petitioner is requesting the Court grant her exclusive possession of her non-marital residence during the pendency of the divorce so as to preserve and protect the residence and prevent Petitioner and the children from being exposed to Respondent's drunken outbursts. 8. It is anticipated the Respondent Jaime A. Carrion does not concur with this Request for Exclusive Possession. 9. This case has not been previously assigned to a Judge. WHERFORE, Petitioner Melissa K. Carrion respectfully requests this Court to enter the attached Proposed Order granting exclusive possession of her non-marital residence to Petitioner, and further removing Respondent from said residence and further directing Husband Jaime A. Carrion not be permitted to enter the premises without advance notice to Petitioner and only at 2 such times as Petitioner agrees and where Petitioner is present, and grant any further relief this Court deems appropriate. Respectfully submitted, Dated: By: Esquire Camp Hill, PA 17011 Telephone No. 717-737-5890 Attorney for Plaintiff 3 3 820 Market Street VERIFICATION I, Melissa Carrion, hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn verification to authorities. WL DATEAIWI O? Melissa arrion CERTIFICATE OF SERVICE I, Joanne Harrison Clough, Esquire, do hereby certify that on this date I served a copy of the foregoing document by United States First Class Mail to the following individual set forth below: Jaime A. Carrion 4135 Wertzville Road Enola, PA 17025 Date: Joanne Harrison Clough, Esquiq Attorney ID No. 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff () r.,s r? ? C7 177 C_) r w!w ~ , 1 y MELISSA K. CARRION IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. • 2007-6582 CIVIL ACTION LAW JAIME A. CARRION IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, November 07, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at_ 39 West Main Street, Mechanicsburg, PA 17055 on Monday, December 03, 2007 at 9:00 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/ Dawn S. Sunda 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 4"Ap:fz)-?k-v --?z v7w . 'eAv f 1--r" A 1ti. L1?'-? 1 ' v JOANNE HARRISON CLOUGH, PC BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff MELISSA K. CARRION, Plaintiff V. JAIME A. CARRION, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. CIVIL ACTION -LAW IN DIVORCE AND CUSTODY ORDER FOR EXCLUSIVE POSSESSION AND NOW, this day of-- 2007, upon review of the attached Petitioner Melissa K. Carrion's Petition for Exclusive Possession of the Marital Residence, it is HEREBY ORDERED and DECREED that Melissa K. Carrion shall have exclusive possession of the marital residence located at 4135 Wertzville Road, Enola, Cumberland County, Pennsylvania until further order of Court. It is specifically directed that the Respondent, Jaime A. Carrion shall only have access to the marital residence after requesting access through counsel and scheduling a specific date and time to appear at the marital residence when Petitioner shall also be present. BY THE COURT: PUN?C)L..` J^`? ?ydlt ?? i Z .Z Wd 9Z h0N LOUY c JOANNE HARRISON CLOUGH P BY: JOANNE C Attorney I.D. N0 CLOUGH, ESQUI 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737_5890 Attorne for pl Ciff MELISSA K m P RRION, Q 1 ? k ` mhff : IN THE C CUMBERLAND OF COMMON PLEAS V. CONY, PENNSYLVANIA JAIME A CARRION NO. _ b? Defendant CIVIL ACTION - LAW O IN DIVORCE AND CUSTODY VER OF COURT AND NOW3 this day of 293 to 4w EmergencY R 3 2007, upon review of the Relief, it is hereby ORDERED and DECREED as follows: or child Matthew Angel Carrion shall be custody of the Plaintiff, Melissa K. C anion Emer ,the mother, placed in the temporary Physical gency Relief. ? pending the hearing on th b. The Defendant shall e Petition for Wertzville Road not remove the child from the residence located at County' Pennsylvania 4135 C. 17025. The minor child Matthew Angel Carrion shall not be removed The Defendant shall not re from Penns move the child Matthew, Angel Carrion Ylvania. from school. A hearing on the Petition for Emergenc Y Relief shall be held on the oZ? 2007 in court room number day of Courthouse located at the Q - at One Courthouse S Cumberland Co 9uare5 Carlisle Pennsylvania ?? . n B Y THE COURT: J. zUZ DEC 0 7 2007 M MELISSA K. CARRION Plaintiff vs. JAIME A. CARRION Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007-6582 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 10th day of ou-e,ft. y , 200 7, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Melissa K. Carrion, and the Father, Jaime A. Carrion, shall have shared legal custody of Matthew Angel Carrion, born April 22, 2001. Major decisions concerning the Child including, but not necessarily limited to, his health, welfare, education, religious training and upbringing shall be made jointly by the parties after discussion and consultation with a view toward obtaining and following a harmonious policy in the Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Child. Neither party shall attempt to alienate the affections of the Child from the other party. Each party shall notify the other of any activity or circumstance concerning the Child that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports or information given to either party as a parent as authorized by statute. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have reasonable, liberal periods of partial custody with the Child, with the times to be arranged by agreement between the parties. The parties shall make arrangements for the Father's sister, Myra Diaz, or other responsible adult selected by agreement between the parties to be present at all times during the Father's periods of custody. 4. The Father shall not consume alcohol within the 24 hours preceding his periods of custody with the Child or during his periods of custody with the Child. 5. The Father shall not remove the Child from the Mother's residence except for a period of partial custody as provided in this Order. The Father shall not remove the Child from his school, nor 5 from the Commonwealth of Pennsylvania except with the express advance written consent of the Mother. 6. The Father may file a request for the scheduling of an additional custody conciliation conference, if necessary to review the custodial arrangements set forth in this Order. BY THE COURT, N? -? La M. L. Ebert, Jr. J. cc: vfoanne Harrison Clough, Esquire - Counsel for Mother /aime A. Carrion, Father I ` :C III 0 1 3 3,0 I1i01 BY: JOANNE HARRISON CLOUGH ESQUIRE Attorney I.D.No. 36461 3820 Market Street 2013 JUL 18 AH W 53 Camp Hill,PA 17011 Telephone: (717)737-5890 CUMBERLAND I OOT Y PENNSYLVANIA Attorney for Plaintiff MELISSA K. CARRION, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-6582 Civil Term JAIME A. CARRION, CIVIL ACTION-LAW Defendant IN DIVORCE AND CUSTODY PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the Divorce Complaint filed on October 30, 2007 in the above captioned matter. We were unable to serve the Defendant within 30 days of date of filing of this Action. Respectfully submitted, JOA E HARRISON 1, GH, PC / DATE: ✓ i Joanne I arrison Clough, squire Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 -21J ��S C-„ � SHERIFF'S OFFICE OF CUMBERLAND COUNTVrcr`�' Ronny R Anderson I Sheriff Jody S Smith Chief Deputy ' ` s ° CS C}` Richard W Stewart Solicitor OFF ICE OF THE SKRIFr Melissa Kaye Carrion Case Number vs. Jaime Antonio Carrion 2007-6582 SHERIFF'S RETURN OF SERVICE 0713112013 03:01 PM-Deputy Tim Black, being duly sworn according to law, served the requested Complaint in Divorce by"personally" handing a true copy to a person representing themselves to be the Defendant,to wit: Jaime Antonio Carrion at 902 Market Street, Lemoyne Borough, Lemoyne, PA 17043. TIM BLA K, DEPUTY SHERIFF COST: $46.54 SO ANSWERS, August 01, 2013 RbNW R ANDERSON, SHERIFF ACS Cou-ty5uite Sheriff,Te€eosof;,Inc_ Melissa K Carrion (IN THE COURT OF COMMON PLEAS OF PLAINTIFF, ( (Cumberland COUNTY, PENNSYLVANIA . V. ( ry► szo, -my( CIVIL DIVISION Z r-n-- Jaime A Carrion (NO: 07-6582 v DEFENDANT. -t t , AFFIDAVIT OF CONSENT "Pt* Zit 1.A complaint in Divorce under Section 3301 (c)of the Divorce Code was filed on(date:) Octob44 20 2.The Marriage of the Plaintiff and Defendant is irretrievable broken and ninety days elapsed from the date of filing and Complaint. 3.I consent to the entry of a final decree of Divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. Section 4904 relating to unsworn falsification to authorities. Date lq V id( (3 aintiff Sworn o and Subscribed before m this„k,dayof,4%t,.P/n 14,20 jj' /4, /7 - • • ary 'u• ic DANIELLE MARIE KEPNER Notary Public LEMOYNE BORO_,CUMBERLAND COUN'v My Commission Expires Sep 16 20 1 d Melissa K Carrion ( IN THE COURT OF COMMON PLEAS OF PLAINTIFF, ( (Cumberland COUNTY, PENNSYLVANIA V. ( . ( CIVIL DIVISION 8• Jaime A Carrion (NO: 07-6582 O DEFENDANT. "� AFFIDAVIT OF CONSENT _T# 311P111 z-- 1.A complaint in Divorce under Section 3301 (c)of the Divorce Code was filed on(date:) Octob% , 2 2.The Marriage of the Plaintiff and Defendant is irretrievable broken and ninety days elapsed from tilt daft of filing and Complaint. 3.I consent to the entry of a final decree of Divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. Section 4904 relating to unsworn falsification to authorities. Date [-G ‘7/—2c/f3 P4ftintiff Oefei'atnt Swor to and scribed before me this u of O (14 VIZ.,20 Notary Pt,. is j COIMt101AMEAUNSIF PENNBYLVNIIA NbTA AL SEAL DANIELLE MARIE KEPNER Notary Public LEMOYNE BORO.,CUMBERLAND COUNTY My Commission Expires Sop 16,2017 z Or 13 5CIJ 1(3' iHII: 'I JOANNE HARRISON CLOUGI-I,PC 'u1`j Et L q p r✓Q�1 BY: JOANNE IIARRISON CLOUGII,ESQUIRE PENNS YLVAHIA Attorney I.D. No. 36461 3820 Market Street Camp hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff MELISSA K. CARRION, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 07-6582 JAIME A. CARRION, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY PRAECIPE TO TRANSMIT RECORD UNDER § 3301 (c) OF THE DIVORCE CODE To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: (a) Date of service: August 1,2013 (b) Manner of service: Service by Sheriff. Affidavit of Service filed: August 5, 2013. 3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code: (a) By the Plaintiff: signed on November 4, 2013 and filed November 4, 2013. (b) By the Defendant: signed on November 4, 2013 and file November 4, 2013. (c) Date of execution of Waiver of Notice of Intention to File Praecipe to Transmit Record: (d) By the Plaintiff: signed on November 4, 2013 and file November 4,2013. (e) By the Defendant: signed on November 4, 2013 and file November 4, 2013. 4. Related claims pending: NONE. DATED: � ' 4111 Joanne larrison Clou :squire Attorney ID No. 3646 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Melissa K. Carrion : IN THE COURT OF COMMON PLEAS OF MELISSA K. CARRION : CUMBERLAND COUNTY, PENNSYLVANIA • V. JAIME A. CARRION NO. 07-6582 DIVORCE DECREE AND NOW, 14 Noopir,ibb,,.2o 13 , it is ordered and decreed that MELISSA K. CARRION , plaintiff, and JAIME A. CARRION , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") ^ .= By the o it, rte. ` ~ - -` of Thomas A.Placey J ommon •eas udge • Attest: Prothonotary �'. , `. Qert Copy mailed ato03 h !io-im.v 4(.4 mai led Flo c ��a S 13 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION—LAW Plaintiff () -� FILE NO. J�01 , VS. IN DIVORCE -•`—. v , u� ry -{). —<> Cri CD , Defendant r ;j NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 1 ,44,h day of hereby elects to resume the prior surname of and gives this written notice pursuant to the provisions of 54 P.S. 704. r DATE: W _ Signature Signature of name Bing resumed COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the c> 4k day day of L!j� 20 / before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. L -el Notary Public �thonotary.Cumberland County,Carlisle,PA fv CommSssion Expires the First Monday.of Jan.2014