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HomeMy WebLinkAbout09-6529F:\DOCS\FL\DIV\Quesenberry.Torrence - 3301(c) complaint & custody complaint.wpd ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET NEW CUMBERLAND PA 17070 (717) 774-7435 ATTORNEY FOR PLAINTIFF TORRENCE R. QUESENBERRY, Plaintiff V. ERIN MICHELLE (GURINGO) QUESENBERRY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 0q - (P-5029 GV; ( Term CIVIL ACTION - LAW IN DIVORCE & IN 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 at the Cumberland County Courthouse, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 ELIZABETH B. STONE, ESQ ATTORNEY ID NO. 60251 414 BRIDGE STREET ,NEW CUMBERLAND PA 17070 (717) 774-7435 (ATTORNEY FOR PLAINTIFF lITORRENCE R. QUESENBERRY, : IN THE COURT OF COMMON PLEAS OF it Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA G Sat 9 C?u? / Gc--• v. NO. 0q. ERIN MICHELLE (GURINGO) CIVIL ACTION - LAW QUESENBERRY, Defendant IN DIVORCE & IN CUSTODY COMPLAINT 1. The Plaintiff in this action is TORRENCE R. QUESENBERRY, an adult individual, who currently resides at 210 Church Road, Etters, Pennsylvania 17319. 2. The Defendant in this action is ERIN MICHELLE (GURINGO) QUESENBERRY, an adult individual, who currently resides at 4021 Cherokee Avenue, Camp Hill, Pennsylvania 17011. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on March 16, 2002, in Camp Hill, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 7. The Plaintiff avers that two children, DRAKE MATTHEW QUESENBERRY, born October 10, 1999, age nine, and MAKENNA DAYNE QUESENBERRY, born January 11, 2004, age five, have been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of divorce. COMPLAINT FOR CUSTODY 1 The Plaintiff in this action is TORRENCE R. QUESENBERRY , an adult individual, who currently resides at 210 Church Road, Etters, Pennsylvania 17319. 2. The Defendant in this action is ERIN MICHELLE (GURINGO) QUESENBERRY, an adult individual, who currently resides at 4021 Cherokee Avenue, Camp Hill, Pennsylvania 17011. 3. Plaintiff seeks custody of DRAKE MATTHEW QUESENBERRY and MAKENNA DAYNE QUESENBERRY who resides at 4021 Cherokee Avenue, Camp Hill, Pennsylvania 17011. DRAKE MATTHEW QUESENBERRY is nine years of age having been born on October 10, 1999. MAKENNA DAYNE QUESENBERRY is five years of age having been born on January 11, 2004. DRAKE MATTHEW QUESENBERRY was born out of wedlock. MAKENNA DAYNE QUESENBERRY was not born out of wedlock. The children are presently in the custody of the mother, ERIN MICHELLE (GURINGO) QUESENBERRY who resides at 4021 Cherokee Avenue, Camp Hill, Pennsylvania, 17011. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESS DATES Torrence R. Quesenberry 4021 Cherokee Ave. birth-present Camp Hill, PA Erin Michelle Quesenberry 4021 Cherokee Ave. birth-present Camp Hill, PA The mother of the children is ERIN MICHELLE (GURINGO) IQUESENBERRY, currently residing at 4021 Cherokee Avenue, Camp Hill, Pennsylvania 17011. She is married. The father of the children is TORRENCE R. QUESENBERRY, currently residing at 210 Church Road, Etters, Pennsylvania 17319. He is married. 4. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following lpersons: NAME Debbie L. Fogle RELATIONSHIP Plaintiffs, mother 5. The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons: NAME RELATIONSHIP Drake Matthew Quesenberry Defendants, son Makenna Dayne Quesenberry Defendants, son x 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a Court of this Commonwealth. Plaintiff does not know of a person not a party to the (proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: (a) The children have resided with the father since birth, who has provided a continuous living relationship with the children; (b) The father is able to provide a stable home and family type environment for the children allowing the children opportunity to spend time with the children's mother consistent with a schedule the parties have arranged between themselves. 8. 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. WHEREFORE, plaintiff requests the court to grant custody of the children. STONE LaFAVER &LE Date: -2125109 Eliz B. ne, Esquire S reme Cou ID # 60251 414 Brid Street, P.O. Box E New land, PA 17070 Tel C er one 717-774-7435 Attorneys for Plaintiff V E R I F I C A T I O N TORRENCE R. QUESENBERRY states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth. in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. TORRENCE R.-- QUESENBERR Date: ?? F LEC- 2009 SE'P 29 Nit 2: u G,U iY 4440 . So P Q AM Y ek 1+ 843 I ! aslall ,Pko , 4 a+ I F:\7OCS\FL\DIV\Quesenberry.Torrence - Affidavit of Service.wpd ELIZABETH B. STONE, ESQ ,ATTORNEY ID NO. 60251 1414 BRIDGE STREET NEW CUMBERLAND PA 17070 1 (717) 774-7435 ATTORNEY FOR PLAINTIFF TORRENCE R. QUESNBERRY, Plaintiff v. ERIN MICHELLE (GURINGO) QUESENBERRY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6529 CIVIL ACTION - LAW IN DIVORCE & IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce and Custody in the above captioned matter on the defendant, Erin Michelle (Guringo) Quesenberry, 4021 Cherokee Avenue, Camp Hill, PA 17011, by United States certified mail, postage prepaid,] restricted delivery, on Octo er 1, 2009, as evidenced by the attached certified mail re n re ems. ,fizabeth B etone, Esquire Attorney a Law SWORN TO AND SUBCRIBEDi before me this 5 r' day of October 2 9. otary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL JENNIFER A. MEARKLE, Notary Public New Cumberland Boro. Cumberland Co. My Commission Expires July 7, 2012 z U T oa J J T N la a e 3 -J O O 03 O ki Ln O O O O ru Ln ru -a O O? ..0 k-i RIF?i=a=M .. CF T -P€?OT1-1(NOTARf 2009 OCT -6 PM 1: 29 CU,it?:. - ;!,-,, -',LINTY REANSYLVANIA TORRENCE R. QUESENBERRY IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V 2009-6529 CIVIL ACTION LAW ERIN MICHELLE (GURINGO) QUESENBERRY IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, October 07, 2009 , 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 Thursday, October 29, 2009 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. 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/ Dawn S. Sunda 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 A'T'TORNEY 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 5 2 ZIlEl9 OCT '$ AM It', oo? ? /-n?t L L L 4c) )Q ? ? ie A?--, J""Ltqcc 46 44? TORRENCE R. QUESENBERRY Plaintiff VS. ERIN MICHELLE (GURINGO) QUESENBERRY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-6529 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 233 day of 1' ,e_/-? , 2009, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Father, Torrence R. Quesenberry, and the Mother, Erin M. Gringo Quesenberry, shall have shared legal custody of Drake M. Quesenberry, born October 10, 1999, and Makenna D. Quesenberry, born January 11, 2004.Major decisions concerning the Children including, but not necessarily limited to, their 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 each Child's best interest. Neither party shall impair the other party's rights to shared legal custody of the Children. Neither party shall attempt to alienate the affections of the Children from the other party. Each party shall notify the other of any activity or circumstance concerning the Children 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 parties shall have physical custody of the Children in accordance with the following 16 week rotating schedule; A. BLOCK I: During the four-week block when the Father works on Monday through Thursday from 5:00 a.m. until 5:00 p.m., the Father shall have custody of the Children from Thursday after work at 6:00 p.m. through Sunday at 7:00 p.m. In addition, the Father shall be entitled to have an evening period of custody with the Children on a school night on either Monday, Tuesday or Wednesday as arranged by agreement between the parties. B. BLOCK II: During the four weeks when the Father works from Thursday through Sunday from 5:00 a.m. until 5:00 p.m., the Father shall have custody of the Children on Mondays, 3 Tuesdays and Wednesdays from 4:00 p.m. until 7:00 p.m. with optional overnights if the Father is able to take the Children to school the following morning. C. BLOCK III: During the four weeks when the Father works from Monday through Thursday from 5:00 p.m. through 5:00 a.m., the Father shall have custody of the Children from Friday at 4:00 p.m. through Sunday at 7:00 p.m. D. BLOCK IV: During the four weeks when the Father works from Friday through Tuesday from 5:00 p.m. through 5:00 a.m., the Father shall have custody of the Children on Tuesdays, Wednesdays and Thursdays from 4:00 p.m. until 7:00 p.m. with optional overnights if the Father is able to take the Children to school the following morning. E. During the transitional weeks between Block II and Block III and between Block IV and Block I, when the Father is unable due to the transitional schedule to exercise all of his periods of custody specified in this provision, the parties shall arrange by agreement to maximize the Father's time with the Children when he is not working. F. The Mother shall have custody of the Children at all times not otherwise specified for the Father. 3. The parties acknowledge that it is their goal in establishing the foregoing custody schedule to maximize the Father's nonworking time with the Children. In the event there are changes to the Father's work schedule, the parties shall cooperate in making adjustments in a manner that will continue to ensure that the Father has custody of the Children as much ss possible when he is not working. The Father shall provide the Mother with as much notice as possible of changes to his work schedule and shall provide to the Mother a copy of his work schedule upon receipt from his employer. 4. The parties shall share having custody of the Children on holidays as follows: A. Thanksgiving: The Thanksgiving period of holiday custody shall run from 9:00 a.m. until 8:00 p.m. on Thanksgiving Day. The Mother shall have custody of the Children on Thanksgiving in odd numbered years and the Father shall have custody in even numbered years. B. Christmas: In every year, the Father shall have custody of the Children on Christmas Eve from an agreed upon beginning time through 11:00 p.m. and the Mother shall have custody of the Children from Christmas Eve at 11:00 p.m. through Christmas Day. The Father shall be entitled to have a period of custody with the Children for at least three hours early on Christmas Day to enable the Father to give the Children their gifts. The Mother shall have custody on Christmas Day by 5:00 p.m. for the remainder of the day for celebration of the holiday with her family. C. Easter: The holiday period of custody on Easter shall run from 9:00 a.m. until 8:00 p.m. on Easter Sunday. The Father shall have custody of the Children for Easter in even numbered years and the Mother shall have custody in odd numbered years. D. Mother's Day/Father's Day: In every year, the Father shall have custody of the Children for Father's Day from 9:00 a.m. until 8:00 p.m. and the Mother shall have custody of the Children for Mother's Day for the same time period. E. Memorial Da /July Fourth/Labor Day: The parties shall share having custody of the Children for the Memorial Day, July Fourth, and Labor Day holidays as arranged by agreement. F. Parents' Birthdays: Each parent shall be entitled to have custody of the Children on his or her birthday for a sufficient period to celebrate the occasion. G. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. H. The parties shall cooperate in making every effort to accommodate each party's request to have the Children for special family events. 5. Each party shall be entitled to have custody of the Children for up to three weeks for vacation each year upon providing at least 30 days advance notice to the other party. One week of the three weeks may be scheduled in a single block of time and the remaining two weeks shall be scheduled in smaller blocks of time as arranged by agreement. The party providing notice first shall be entitled to preference on his or her selection of vacation dates under this provision. Each party shall provide the other with advance notice of the address and telephone number where the Children can be contacted during vacation periods. 6. Unless otherwise agreed, the parent receiving custody shall be responsible to provide transportation for the exchange of custody. 7. In the event a party will be unavailable to provide care for the Children during his or her period of custody, that parent shall first offer the other parent the opportunity to provide care for the Children during that party's unavailability before contacting third party caregivers. 8. Each party shall ensure that the Children attend their regularly scheduled activities during his or her periods of custody 9. The parties agree that the regular physical custody schedule set forth in this Order shall be implemented on a trial basis. Within four months of the date of this Order, counsel for either party may contact the conciliator to schedule an additional custody conciliation conference, if necessary to review the custodial arrangements. 10. Neither party shall do or say anything which 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. Both parties shall ensure that third parties having contact with the Children comply with this provision. 11. 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,) J. cc: Elizabeth B. Stone, Esquire - Counsel for Father Jeanne B. Costopoulos, Esquire - Counsel for Mother v TORRENCE R. QUESENBERRY Plaintiff VS. ERIN MICHELLE (GURINGO) QUESENBERRY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-6529 CIVIL ACTION LAW IN CUSTODY 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 subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Drake M. Quesenberry October 10, 1999 Mother Makenna D. Quesenberry January 11, 2004 Mother 2. A custody conciliation conference was held on November 16, 2009, with the following individuals in attendance: the Father, Torrence R. Quesenberry, with his counsel, Elizabeth B. Stone, Esquire, and the Mother, Erin M. Guringo Quesenberry, with her counsel, Jeanne B. Costopoulos, Esquire. 3. The parties agreed to entry of an Order in the form as attached. 1nyjj ? l 7, .106 9 Date v Dawn S. Sunday, Esquire Custody Conciliator 2009 PLO F 2 4 A 11--0 GUI ' ?x fl\div\ I consent&waiver LAW OFFICES OF ELIZABETH B. STONE 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717)909-1500 TORRENCE R. QUESENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : COUNTY, PENNSYLVANIA V. ERIN M. QUESENBERRY, Defendant :NO. 09-6529 r.,, (7? J CIVIL ACTION - IN DIVE ,- use' AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on gept4?nbl 9, 2009, and served October 1, 2009. r 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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 the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 in 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 divorce until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to tion to authorities. (AlI it Date Plaintiff TORRENCE R. QUESENBERRY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : DOCKET NO. 09-6529 ERIN MICHELLE (GURINGO) CIVIL ACTION -LAW QUESENBERRY _= -{ Defendant DIVORCE Co z = r--.. r -<D C) DEFENDANT'S AFFIDAVIT OF CONSENT n-n UNDER SECTION 3301(c) OF THE DIVORCE CODE '- AND WAIVER OF COUNSELING F; C_- z rJ •• • l .? ? r > 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 29, 2009. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 the decree. 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: 1 E ' . Q esenberry 0 TORRENCE R. QUESENBERRY, Plaintiff V. ERIN MICHELLE (GURINGO) QUESENBERRY Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET NO. 09-6529 CIVIL ACTION - LAW DIVORCE ? M y = r z -? = C C-) DEFENDANT'S 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. 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: I Eri. uesenberry LAW OFFICES OF ELIZABETH B. STONE 1300 Market Street, Suite 10 Lemoyne, PA 17043 (717) 909-1500 THE R THO O T;4 2011 JUN -3 PM 12:1 1 aUMBERLAQ c-OUN i Y ?ENNSYl VA IA TORRENCE R. QUESENBERRY, Plaintiff V. ERIN M. QUESENBERRY, Defendant § IN THE COURT OF COMMON PLEAS OF § CUMBERLAND COUNTY, PENNSYLVANIA § NO. 09-6529 § CIVIL ACTION - IN 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 October 1, 2009. Affidavit of Service filed on October 6, 2009. 3. Date of Execution of the Affidavit of Consent Required by Section 3301(c) of the Divorce Code: by Plaintiff on (1(11 ; by Defendant on 5(2 (h 4. Related Claims Pending: no other marital claims 5. Date of Filing Waivers of Notice: Plaintiff's wa' er ' em filed with this Praecipe; Defendant's waiver is being filed w' is Pra ipe. Mizabeth y. S?,dne, Esquire Attorne f laintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TORRENCE R. QUESENBERRY V. ERIN M. QUESENBERRY : NO 09-6529 DIVORCE DECREE o-9%0 ;.41. AND NOW, awr4 ? , it is ordered and decreed that TORRENCE R. QUESENBERRY plaintiff, and ERIN M. QUESENBERRY , 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.") None. By urt, II J. Prothonotary L, 7,/l- Cede®py "a //,?c/ 7LO Alohi?e i dDPY d she Cos AyoaA2s