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HomeMy WebLinkAbout09-7818STEVEN A. FURMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 09- 7F/F C L4 -Ti - TRACIE L. FURMAN, Defendant IN DIVORCE/CUSTODY NOTICE 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 Court House, High and Hanover Streets, Carlisle. 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 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. STEVEN A. FURMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 4 9 - -7 9/ Try. TRACIE L. FURMAN, Defendant IN DIVORCE/CUSTODY COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Steven A. Furman, who currently resides at 520 Penn Ayr Road, Camp Hill, Cumberland County, Pennsylvania, since July, 2006. 2. Defendant is Tracie L. Furman, who currently resides at 520 Penn Ayr Road, Camp Hill, Cumberland County, Pennsylvania, since July 2006. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on June 15, 2002, in Lock Haven, 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 marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. 9. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. COUNT I. COMPLAINT FOR CUSTODY 1. 2 3 4. 5. Plaintiff is Steven A. Furman, who resides at 520 Penn Ayr Road, Camp Hill, Cumberland County, Pennsylvania 17011. Defendant is Tracie L. Furman, who resides at 520 Perm Ayr Road, Camp Hill, Cumberland County, Pennsylvania 17011. Plaintiff seeks custody of the following children: Name Present Residence DOB AAee Madison M. Furman 520 Penn Ary Road 9/26/03 6 years Camp Hill, PA 17011 Elizabeth A. Furman 520 Penn Ayr Road 1/6/06 3 years Camp Hill, PA 17011 The children were not born out of wedlock The children are presently in the custody of Steven A. and Tracie L. Furman, who resides at 520 Penn Ayr Road, Camp Hill 17011. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons Steven A. and Tracie L. Furman List All Addresses 2307 Morris Drive E. Petersburg, PA 17520 Dates 9/03-7/06 Steven A. And Tracie L. Furman 520 Penn Ayr Road Camp Hill, PA 17011 7/06- Present 6. The mother of the children is Tracie L. Furman, who resides at 520 Penn Ayr Road, Camp Hill, Cumberland County, Pennsylvania 17011. She is married. 7. 8 The father of the children is Steven A. Furman, who resides at 520 Penn Ayr Road, Camp Hill, Cumberland County, Pennsylvania 17011. He is married. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons. Name Relationship Tracie L. Furman Wife Madison M. Furman Daughter Elizabeth A. Furman Daughter 9. The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons. Name Relationship Steven A. Furman Husband Madison M. Furman Daughter Elizabeth A. Furman Daughter 10 11. Plaintiff has not participated as a party, witness, or in any another capacity, in other litigation concerning the custody of the children 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 and claims to have custody or visitation rights with respect to the children. The best interest and permanent welfare of the children will be served by granting the relief request because: Plaintiff has undertaken and performed the parental responsibilities for the children and could provide equal care in a joint custody situation. Plaintiff is able to provide the care and nurture which the children need for healthy development in a joint custody situation. A Court Order of custody and structured visitation is desired so that the Plaintiff and the children may plan their schedules accordingly, and so that misunderstandings and unmet expectations regarding custody and visitation can be avoided, and also so that the children are not used in a manipulative fashion. Plaintiff desires to maintain the family household which has been established, and the continued stability of the household is in the best interest of the children. A Court ordered determination of custody is required to avoid continuing conflict between the parties regarding parental responsibility for custody. WHEREFORE, Plaintiff requests this Court grant Plaintiff primary physical custody of the children subject to partial custody by the Defendant. Respectfully submitted, ROMINGER & ASSOCIATES Date: Vincent M. Monfredo, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 206671 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Complaint 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: /_ Z= /09 Steven A. Furman Plaintiff 2 u" 42d. Q ? 33 8.6v j v a . / e yyo,sv CA-1 aaoq J&,_. t 3 3 3 3 / STEVE A. FURMAN IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-7818 CIVIL ACTION LAW TRACIE L. FURMAN IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Monday, November 16, 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 Monday, December 14, 2009 at 10:00 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. 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 10 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 OF THE OWPOMAW ZH3 NOV 18 PM t: 58 PENNSYLV*II 1, 201 1 JUN ! 7 PM I : 2 rUMRERLAND C" 1l1 s t NE JSYL4ANIA. STEVEN A. FURMAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. TRACIE L. FURMAN, Defendant NO. 2009-7818 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of the Defendant, Tracie L. Furman, in the above-captioned matter. Respectfully Submitted, SAIDS, SULLIVAN & ROGERS O Ma tas, Esqu Dated: 11 Attorney . . No. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 PRAECIPE FOR ENTRY OF APPEARANCE Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Defendant, Tracie L. Furman, in the above-captioned matter. Dated: (.P' 14-1 I Respectfully Submitted, Tracie L. Furman, Pro Se 315 W. Walnut Street Lock Haven, PA 17745 STEVEN A. FURMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 09-7818 TRACIE L. FURMAN, Defendant IN DIVORCE/CUSTODY ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Tracie L. Furman, in the above-captioned action and I certify that I am authorized to do so. DATE: By: Lindsay, Esqui for Defendant rn STEVEN A. FURMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 09-7818 TRACIE L. FURMAN, Defendant IN DIVORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 10, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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?g I Zl :z /2011 St en A. Furman/Plaintiff -. -0Z r" M c.. era ? ?? STEVEN A. FURMAN, Plaintiff V. TRACIE L. FURMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09-7818 IN DIVORCE/CUSTODY 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 herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. Date:w / j 7 29011 Steven . Furman/Plaintiff r*i c4 c. , a-Z) ter... C ? rr; r? -? r •? r C STEVEN A. FURMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 09-7818 TRACIE L. FURMAN, Defendant IN DIVORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 10, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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: 6-o- 1( Tracie L. Furman/Defendant ism') r•.a "1 Jr - CD C cz :g ro '?: STEVEN A. FURMAN, Plaintiff V. TRACIE L. FURMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09-7818 IN DIVORCE/CUSTODY 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 herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. Date Tracit.L. Furman/Defendant MC0 :zM C, RMAN rnm IN THE COURT OF COMMON PLE5?@DF , , STEVEN A. FU Plaintiff CUMBERLAND COUNTY, PENNS AlRE?P?''` CIVIL ACTION LAW V. No. 09-7818 `'•' I'D e.-n TRACIE L. FURMAN, Defendant IN DIVORCE/CUSTODY PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service, February 5, 2010, filed June 17, 2011. 3. Date of execution of the affidavit of consent required by § 3301(c) of The Divorce Code: by the Plaintiff June 17, 2011; by the Defendant, June 17, 2011. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 17, 2011. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 17, 2011. Date: C -Z, t , 2011 Vincent M. Monfredo, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 206671 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEVEN A. FURMAN V. TRADE L. FURMAN NO. 09-7818 CIVIL TERM DIVORCE DECREE AND NOW, it is ordered and decreed that STEVEN A. FURMAN , plaintiff, and TRACIE L. FURMAN , 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.") 1 jam By the Court, . It. Ce1-?• ?oP ?( led ?f? ??o lo? -c P d co 5 pelted ote ?? . 6 ?? F TRACIE FURMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION — LAW r NO. _-�jq CIVIL TERM STEVEN FURMAN' r�- Defendant IN DIVORCE <� ? AFFIDAVIT OF SERVICE `•'' ' I, Marylou Matas, Esquire, being duly sworn according to law, hereby deposes and says that on March 12, 2013, she served a true and correct copy of the Qualified Domestic Relations Order upon Wellborn Cabinet 401(k) Profit Sharing, Wellborn Cabinet, Inc., by mailing those documents to the its address at P.O. Box 1210, 38669 Highway 77, Ashland, AL 36251, by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient. Respectfully submitted, SAIDIS, SULLIVAN $ ROGERS --A `VQL � Date: March 21, 2013 Ma s, Esquire ID No. 84919 26 West High Street Law Offices of Carlisle, PA 17013 Sadis (717) 243-6222 Sullivan Counsel for Tracie Furman &. Rogers 26 West High Street Carlisle,PA 17013 i I l 1 I Aba Doi S ftt W end aditm an the mvem / ❑ is OW we am mwm#w CW to ym. B. by C. �Y r AMmd►this card to#w bed*of itw rr W k c m, µJ or on the*ont,It space psmdbs. D. Is address dMfam. from Ibm lf ❑Vft t. 1bYde Addnaaad m: M YEB,eater ddvery address blow: ❑No IT M UDY lalb . ❑ �° 13 kaurod Md ❑ O.D..Romelp Modwmw r 4. PmtfoMd D~Pft F" ❑Yea 7012 2210 0001 1364 0493 '; ,� 0ererarsllaKrn Rroa�t y i