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Home My WebLink About08-0370Tanner Law Offices, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 Telephone (717) 731-8114 Fax (717) 731-8114 BARBARA HUMES, § Plaintiff § V. § RONALD ALAN HUMES, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. J?-370 CI V I l CIVIL ACTION - DIVORCE/CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at One Courthouse Square, Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 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 Fax (717) 731-8114 BARBARA HUMES, § IN THE COURT OF COMMON PLEAS OF Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA § 914 V. § NO. RONALD ALAN HUMES, § CIVIL ACTION - DIVORCE/CUSTODY Defendant § AVISO USTED AA 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 reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantas para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en One Courthouse Square, Carlisle, PA 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVbRCIO 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 ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 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 Fax (717) 731-8114 BARBARA HUMES, § Plaintiff § V. § RONALD ALAN HUMES, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 67- 326 --r,.- CIVIL ACTION - DIVORCE/CUSTODY COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Barbara Humes, by and through her attorney, Tanner Law Offices, LLC, and represents as follows: 1. Plaintiff is Barbara Humes, an adult individual currently residing at 306 South High Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant. is Ronald Alan Humes, an adult individual currently residing at 412 Sharon Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 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 August 17, 1996 in Harrisburg, PA. 5, The marriage is irretrievably broken: Plaintiff and Defendant have lived separate and apart since January 14, 2008, 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 days from the date of the filing of this Complaint, consent to this 6. 7. 8. 9. divorce. Plaintiff filed an action in divorce against the Defendant on January 17, 2003 in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to 03-276. After the parties participated in counseling, Plaintiff withdrew the divorce action on August 28, 2003. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. The Plaintiff has been advised of the 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. Plaintiff requests the Court to enter a decree of divorce. COUNT I - CUSTODY 10. Paragraphs 1 through 9 are incorporated herein by reference as if set forth in their full text. 11. Plaintiff seeks joint legal custody and primary physical custody of the following Children: Name Present Address Age Michael Lee Humes 412 Sharon Avenue 9 Mechanicsburg, PA 17055 (D.O.B.1/6/1999) Alyssa Marie Humes 412 Sharon Avenue Mechanicsburg, PA 17055 Morgan Elizabeth Humes 412 Sharon Avenue Mechanicsburg, PA 17055 12. All three children were born in wedlock. 7 (D.O.B. 3/9/2000) 3 (D.O.B. 10/17/2003) 13. The Children are presently in the custody of the Defendant, Ronald Alan Humes, who resides at 412 Sharon Avenue, Mechanicsburg, Pennsylvania 17055. 14. During the last five years, the Children have resided with the following persons at the following addresses: Persons : Address: Dates: Plaintiff 412 Sharon Ave. 6/2003- present Defendant Mechanicsburg, PA 17055 Plaintiff 1008 Coover St. 1/1999 - 6/2003 Defendant Mechanicsburg, PA 17055 15. The mother of the Children is Plaintiff, Barbara Humes currently residing at 306 South High Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 16. The father of the Children is Defendant, Ronald Alan Humes, currently residing at 412 Sharon Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 17. The relationship of the Plaintiff to the Child is that of mother. 18. The relationship of the Defendant to the Child is that of father. 19. Plaintiff has not participated as a party in other litigation concerning the custody of the Children in a court of this Commonwealth or any other state, other than the filing of the above-referenced divorce action which included a count for custody. 20. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the Children and claims to have custody or visitation rights with respect to the Children. 21. Each parent whose parental rights to the Children have not been terminated and the person who has physical custody of the Children have been named as parties to this action. 22. The best interests and permanent welfare of the Children will be served by granting the relief requested. The quality of the Children's physical, intellectual, moral and spiritual environment would be improved by Plaintiff s continued primary care-taking in the Children's life. Additionally, Defendant's work schedule is not conducive to having the children stay over-night at his residence during the school week. WHEREFORE, Plaintiff requests the Court to grant her joint legal custody and primary physical custody of the Children. COUNT II - Equitable Distribution of Marital Propertx Under Section 3502(a) of the Divorce Code 23. Paragraphs 1 through 22 are incorporated herein by reference as though set forth in full. 24. Plaintiff and Defendant have acquired marital property as defined by the Divorce Code, which is subject to equitable distribution pursuant to Section 3502(a) of the Divorce Code. 25. Plaintiff and Defendant have been unable to agree as to the equitable division of said property, as of the date of the filing of this Complaint. 26. Plaintiff requests that this Court equitably divide, distribute or assign the marital property between the parties. WHEREFORE, Plaintiff prays that a decree in divorce be entered divorcing Plaintiff from the bonds of matrimony between the said Plaintiff and Defendant. Respectfully submitted, By:a?? 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 VERIFICATION I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: Barbara Humes C"'- r` ' s _ :--? .a G- = -- -? -??-. ? ? ? ? c.? b ?. x - F r,? -t -. ??. d ? e ?'°?w BARBARA HUMES IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2008-370 CIVIL ACTION LAW RONALD ALAN HUMES IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, January 22, 2008 , 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 Tuesday, February 05, 2008 at 12:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. 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 q. Custody Conciliator ?0__ 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 Co ,-i ?e III r C AM 8 8 2008 BARBARA HUMES vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff 2008-370 CIVIL ACTION LAW RONALD ALAN HUMES Defendant IN CUSTODY ORDER AND NOW, this 26TH day of March, 2008 , the conciliator, having received no request from counsel or either party to reschedule the custody conciliation conference originally set for February 5, 2008, hereby relinquishes jurisdiction. FOR THE COURT, y Dawn S. Sunday, Esquire Custody Conciliator i"t s?,?}, ?.u! ?} ^ ? }t S? ??1? ' _ S ` f ,tiVJ? TANNER LAW OFFICES, LLC 1300 Market Street, Suite 10 Lemoyne, PA 17043 Telephone: (717) 731-8114 Facsimile: (717) 731-8115 BARBARA HUMES, § Plaintiff § V. § RONALD ALAN HUMES, § Defendant § IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-370 CIVIL ACTION - DIVORCE/CUSTODY PRAECIPE TO WITHDRAW PLAINTIFF'S COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE To the Prothonotary: Please withdraw Plaintiff's Complaint Under Section 3301(c) or 3301(d) of the Divorce Code. The parties have decided to reconcile. Respectfully Submitted, Tabetha A. Tanner, Esquire Attorney for Plaintiff Supreme Court I.D. No.: 91979 P-4 rFl