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Home My WebLink About05-4015 LAURIE MOWERY, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. 0- io/S- ~ ~ BRIAN MOWERY, Defendant : CIVIL ACTION - LAW : 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 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 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, 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 TillS 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, P A 17013-3308 (717) 249-3166 vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; No. 0-::/ ~ 'f 0 IS' ~ ..J~ LAURIE MOWERY, Plaintiff BRIAN MOWERY, Defendant CIVIL ACTION - LAW DIVORCE/CUSTODY COMPLAINT IN DIVORCE UNDER SECTIONS 330I(c) or 330I(d) OF THE DIVORCE CODE The Plaintiff, Laurie Mowery, by and through her attorney, Jeanne B. Costopoulos, Esquire, avers the following: Count I - Divorce L The Plaintiff, Laurie Mowery, is an adult individual who currently resides at 1215 Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant, Brian Mowery, is an adult individual who is believed to be currently residing in Dillsburg, York County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 14, 1988 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 service of the United States or its allies within the provisions ofthe Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. 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. 8. There are three dependent children from this marriage, namely Devon Mowery, bom December 3, 1992, Kyle Mowery, born June 3,1996, and Michael Mowery, born January 13, 1998. 9. This action is not collusive. Count II - Custody 10. The prior paragraphs of this Complaint are incorporated herein by reference thereto. II. The Plaintiff seeks shared legal and primary physical custody of the following children: Name Ages Present Residence Devon Mowery Kyle Mowery Michael Mowery 12 'l2 yrs (DaB 12/3/1992) 9 yrs (DaB 6/3/1996) 7 Y2 yrs (DaB 1/13/1998) 1215 Williams Grove Road Mechanicsburg, P A 17055 12. For over five years, the children have resided with both parties at the marital residence located at 1215 Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. Defendant left the marital residence on May 21. 2005 and the children have remained in the marital residence in the custody of their mother, Plaintiff Laurie Mowery, since that time. 13. The natural mother of the children is Laurie Mowery, Plaintiff, currently residing with the subject children at 1215 Williams Grove Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. The natural father of the children is Brian Mowery, Defendant, currently believed to be residing alone in an apartment in Dillsburg, York County, Pennsylvania. 14. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 15. Plaintiff does not know of a person not a party to the proceedings who has physical custody of any of the children or claims to have physical custody or visitation rights with respect to the children. 16. The best interests and permanent welfare of the children will be served by granting the relief requested because: ( a) Plaintiff is the natural mother of the children and has been their primary caretaker since birth. (c) Plaintiff desires to continue exercising parental duties and enjoys the love and affection of the children. 17. 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. No other persons are known to have or claim a right to custody or visitation of the children to be given notice of the pendency of this action and the right to intervene. WHEREFORE, the Plaintiff respectfully requests this Honorable court to grant her primary physical custody of her children, subject to partial custody/visitation rights of Defendant. RESPECTFULLY SUBMITTED: Dated: r/0J ...--::::: /~ ~ Jeanne B. CostopouIos, Esquire The Executive Offices at Rossmoyne 5000 Ritter Road, Suite 202 Mechanicsburg, P A 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 Fax: (717)790-6019 ATTORNEY FOR PLAINTIFF LAURIE MOWERY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. BRIAN MOWERY, Defendant CIVIL ACTION - LAW DIVORCE/CUSTODY VERIFICATION I, Laurie Mowery, hereby verity that the statements made in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. , i \L/ . i J ''J:Il~~~rY\~ ~j(JL~r- , v , t, Date: 1L~Jlo{J1E Signature: '/ ~ it:-. .......... ~ "\-.l ;;0 ~ o p ~ ~ ~ Vi ~ ~ --- '6 "'""'v ~ IJ c v- cr- ~ C> 0;. o \; ""'t:~\.-t rl1;-n ~t;'~! -< ~: 2::;( > $~:: ~ <::> I/' G) "" = <= U' ".. c.-.:: "" 1 U1 o 1"' ..... :c n,:IJ r lJrTI :00 01 .""t() -"..",", ;:~:q :~M o -~.-\ ?O -< -u ::I; .r LAURIE MOWERY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05-4015 BRIAN MOWERY, Defendant : CNIL ACTION - LAW : CUSTODY PETITION TO ENTER STIPULATION AS AN ORDER OF COURT AND NOW, come the parties, Laurie Mowery and Brian Mowery, and respectfully request the following Stipulation to be entered as an order of court, replacing all prior agreements, stipulations, and orders of court: WHEREAS, the parties, Laurie Mowery (the Mother hereinafter) and Brian Mowery (the Father hereinafter), have born to them three children, namely Devon Mowery, born December 3, 1992, Kyle Mowery, born June 3, 1996, and Michael Mowery, born January 13, 1998 (the Children hereinafter); and, WHEREAS, the parties wish to enter into an agreement relative to custody, partial custody, and visitation of the children; and, WHEREAS, both parties have been provided an opportunity to review the Agreement with the counsel of their choice prior to signing. TIIEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound, the parties agree as follows: 1. L"",,) Custody The parties shall share legal custody ofth., children jointly. They shall consult with each other relative to all major health decisions concerning the children, with a view to having a harmonious policy calculated to promote' the best interest of the children. Each of the parties shall have access to each of the children's medical, dental, hospital, and school records, including test results and report cards; each parent shall permit and encourage communication by the other parent with doctors, teachers, and school administrators regarding the children's health and education progress. 2. Phvsieal Custody The Mother shall have primary physical custody of the children. The Father shall have partial custody of the children as mutually agreed between the parties. 3. Transoortation The parties agree that transportation to and from their residences shall be shared, the details of which can be agreed upon by the parties. 4. Alcohol and Dm2ll During any period of custody, the parties shall not possess or use any un-prescribed controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and guests comply with this prohibition. 5. Address and Phone Numbers of Parties Both Father and Mother must keep each other informed of any changes of address or change of phone number. Any changes in address or phone number shall be promptly forwarded to the other party. 6. Dispanu.inl! Remarks Neither Father nor Mother shall make any disparaging remarks regarding the other parent in the presence of any of the children, such as those that might tend to alienate the affections of the children toward the other parent. Also, each parent shall inform relatives and friends to also refrain from making any disparaging remarks regarding either parent in the presence of the children. 7. Supersedeas of Prior Court Orden This Stipulation shall supersede all prior Court Orders, Stipulations, or Agreements. 8. Modification Any of the provisions of this Agreement may be modified or deleted upon mutual consent/agreement of both parties or upon Petition to the Court for Modification. WHEREFORE, the parties, intending to be legally bound, without coercion or duress of any kind, with the believe that the terms of this Agreement are in the best interest of the children, and with the understanding that this Agreement shall presently be entered as an order of court, hereby set their hands and seals and the date of their acknowledgment. ~~ Signature: La"'Vicry Signature: ~, Brian Mowi~ry Date: Date: Y.Z2.-().... Q, ~-n fl'~ --ob >;;., ~~ ~ .~;~ ~n :1" C.J -I '". ~ C? (~ .-> = c:.' "" ~. G? N ,..f\ .r;: o C.T\ LAURIE MOWERY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 05-4015 CIVIL ACTiON LAW BRIAN MOWERY DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, August 18, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. at OJ Maulove's, 1901 State St., Camp Hill, PA 17011 on Thursday, September IS, 2005 , the conciliator, at 1l: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 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 hearin!!.. FOR THE COURT. By: Isl Melissa P. Greevy, Esq. Custody Conciliator )bl'^ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation 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 ~? ?- ~ ~ -M 5r?.,+l:>.J .JPr 7 ~ ~U; ~~o--st'-j, ~t? ~ ~ ~ 4.- .n 5o.s-e.}> V h\)\;ll ,:'\\':::~ '. }JJ,Jrr,'."- '-',' '::T::\;nJ Z I ;11 lid SZ ~rw sooz AI:IVI C;~0HJO::Jd 3H.l. :JO - 381:1oiO--o311:J Iy R'=C ,: '\:::'" ':1'; Co r ""'" . ~ L:.; ~ ~.J /-1..,... -.r... ",,<J'.J;J r LAURIE MOWERY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05-4015 BRIAN MOWERY, Defendant : CIVIL ACTION.. LAW : CUSTODY AND NOW, this ORDER OF COURT 2'jlldaYOf f\ '\\. , 2005, upon consideration of the within Petition to Enter Stipulation as an Order of Court which is incorporated herein by reference, IT IS HEREBY ORDERED AND DECREED that said Petition is hereby granted and its contents are hereby approved and adopted as an Order of Court with full weight and effect as if it had been set forth in full hereinafter. It is binding and enforceable upon the parties hereto. BY THE COURT: ~ ~? , ,/ I fL, ^ ,/~ ", o/{ / . "- :T. , rtt r \\ '" '? t \:/';;\l\Jt\\<\S;<\~;.~(i ) ",Y'" ,~,,' ;-', ,,<c'..'n".... \j.\'\l\ ,',J ,..,'c' " "~,,.~\ h.J 9 \ :~ \:It\ O~ ;)f\~ ~UU~ , ,,,,, ",,' , -,' I' :lel }\dl.J~U'i',\\.)'r\t;,)GG ::\\1 ' ;r::.i\~\c:\D-c.rn\:i jRECEIVED SEP 202005 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4015 CIVIL TERM CIVIL ACTION - LAW LAURIE MOWERY, v. BRIAN MOWERY, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 15th day of September, 2005, upon notification that the parties have entered a stipulation and the Court has entered an Order thereon dated August 29, 2005, the Custody Conciliator hereby relinquishes jurisdiction of the matter. The Custody Conciliation Conference previously scheduled for September 15, 2005 at 11 :00 a.m. is hereby CANCELED. Counsel for the Plaintiff shall serve the Defendant Father with a copy of this Order. FOR TH~ k:~ ~h Melissa Peel Greevy, Esquire Custody Conciliator Dist: 4nne B. Costopoulus, Esquire. 5000 Ritter Road. Suite 202. Mechanicsburg. PA 17055-6922 .l"rian Mowery, 26-C Dogwood Lane, DiIIsburg, PA 17019 :258128 fr: ~ wR 0"- rr:Q 9~ o 8g: ~l1J "'-iE' ~ \.0 ..:1- m ::c 04 N 0- W U) en = = '" ~;= f3~ ~.:,~;~ :((() -,:;:-: ...,'-:" .:)(-Cj :]fa:. ::::> <...1 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4015 CIVIL TERM LAURIE MOWERY, v. CIVIL ACTION - LAW BRIAN MOWERY, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 15th day of September, 2005, upon notification that the parties have entered a stipulation and the Court has entered an Order thereon dated August 29, 2005, the Custody Conciliator hereby relinquishes jurisdiction of the matter. The Custody Conciliation Conference previously scheduled for September 15, 2005 at 11 :00 a.m. is hereby CANCELED. Counsel for the Plaintiff shall serve the Defendant Father with a copy of this Order. Melissa Peel Greevy, Esquire Custody Conciliator Dis!: Jeanne B. Costopoulus, Esquire, 5000 Ritter Road, Suite 202, Mechanicsburg, PA 17055-6922 Brian Mowery, 26-C Dogwood Lane, DiUsburg, PA 17019 :258128 \/j(-~'v"i\'L\S,i\jr.J:~d }J.Nn~:'-':-:' :"....:.-~i:/\!n:) 9 ~ :6 Ill} 82 d3S SOOl }"HV10HOH10Ud 3Hi :10 381:1:10-o31l:J -"RECEIVED SEP 202005 LAURIE MOWERY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 05-4015 CIVIL TERM v. CIVil ACTION - LAW BRIAN MOWERY, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 15th day of September, 2005, upon notification that the parties have entered a stipulation and the Court has entered an Order thereon dated August 29, 2005, the Custody Conciliator hereby relinquishes jurisdiction of the matter. The Custody Conciliation Conference previously scheduled for September 15, 2005 at 11 :00 a.m. is hereby CANCELED. Counsel for the Plaintiff shall serve the Defendant Father with a copy of this Order. Melissa Peel Greevy, Esquire Custody Conciliator CtJMSERLAND COUNTY COURT ADMINISTRATOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013 ReCEIVED OCT 03 20m: s JOHNSO U;J lCWART AZb DUFFIE WE/DNEil ~-~ BRiAN 'MOWERY , 26-C DOOWOOO-LANE DILLSBURG, PA 17n1Q A 0 INSUFFICIENT ADDRESS Oc 0 ATTEMPTED NOT KNOWN 0 OTHER o 0 SUCH NUMBER! STREET S ~DT DELIVERABLE AS ADDRESSED r ~UNABLE TO FORWARD i 70 i '3# is.: LAURIE MOWERY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05-4015 BRIAN MOWERY, Defendant CIVIL ACTION - LAW DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on August 5,1995. 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. 94904 relating to unsworn falsification to autborities. ttt. . , , , ., if , 1p$t-' " ;1\ Date: : ---- -- 2- ;;: ""tit):-) II""\'"),-n ;Z:'T' 7i_ (j~~ -''-. ..~-' '..;:< ", .'<. ':?~t:) 'y'C ~ -~- ~ (;.... ~ ~ ..." :::;:: ~ :C-n ,np: -om :.0<:( 9\~, :L..,:'1 (~f) :/':'fn Q A ;e: ~ - .. - c.J'\ - LAURIE MOWERY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05-4015 BRIAN MOWERY, Defendant CIVIL ACTION - LAW DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING I. A Complaint in Divorce under Section 330I(c) of the Divorce Code was filed on August 5, 2005. 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. 94904 relating to unsworn falsification to authorities. Date: J - ~c> -u~ Si,",hrro~C-~ Brian Mowery --------- ..------- r;;;; ~ '- ~ ~ (> ~ -;:JC':': C[) r~' &}<~,~- ;:So < .......,::...... ~(~ /- '2 -- -0 ~ Q, -' -c.-,-. ~-~'< ..~tJ 'O~.) '::\~-~~ 0-;" %;;.n 9 ~ - - ~ -- LAURIE MOWERY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05-4015 BRIAN MOWERY, Defendant CIVIL ACTION - LAW DIVORCE PLAINTIFF'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! 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. 94904 relating to unsworn falsification to authorities. Dated: ~ Signature: L n 1 . \.- (0vVl / .---------- ~ ~ c.c- ~ l:j g ""OB~; \n{'i" ~~~ ''::- ?;;() ~--,' ' 5.'(::: ,,~ :z -- ------------ -~ ~ ------- ~- -0 ~ q. .....I ~:!l -orrG ;9,9 '::.'It.J ~J::;\ ,.7(') ~~rn g ?ii ..... - - c), ---~---._- LAURIE MOWERY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05-4015 BRIAN MOWERY, Defendant CIVIL ACTION - LAW DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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! 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. Dated: 1-[.0- 06 s;_.il..~ Brian Mowery o c -p !:,... -0 CD me!;-, Z'" U)~~: -<;;..~ ~'-. !.;:c; ...~(, j;:t-f.:: 3 ~ ~ "b- e:..- ~ N -.l ~ s:!:o rn r: -om ~J9 7:10 ::':-::f-i "" (55 ~ ~Z:f1'1 - ~\ - ~ cJ1 LAURIE MOWERY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05-4015 BRIAN MOWERY, Defendant CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: I, Jeanne B. Costopoulos, Esquire, verifY that the Complaint in Divorce was served upon the Defendant indicated above on August 11,2005, by first class, Certified Mail No. 7000 15300001 6001 9067, postage prepaid, return receipt requested, restricted de1ivel)', pursuant to the requirements ofPa.R.C.P. 91930.4. BY: L",,,", &qW~ ATTORNEY FOR PLAINTIFF 3803 Gettysburg Road Camp Hill, PA 17011 Phone: (717) 920-2500 PA Supreme Ct. ID No. 68735 DATE: //z)/zftfp . Complete items 1,2, and 3. Also complete item 4 jf Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: en (}.\'\ V"o i,J~('l1 '2~ C bOjWa-oct' 4AAe.. })(\\s~W'j, p~ 170lcr e D. Is delivery address different item 1? If YES, enter delivery address below: Restricted Delive 3. Service Type ..Q'Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C.O.D. 2. Article Number (fransfer from service label) PS Form 3811, August 2001 7000 I<)'}O DooI b ()O \ ~ qo ~ 7 4. Restricted Delivery? (Extra Fee) Domestic Return Receipt 10259S-01-M-2509 ...,., ~ d' c..- ~ ~ ~ -,j(:1\ rnp -'y"',". zt_. ~~L, ':.c: -- "'="'..--. ~c":; J>C Z ::<! ..------ -c :;;t: ~ S;-n r"r;; ~o 0~ , ,~L), :::t:::f( ~;t~ g -;z.;:; :tt - - (.fl LAURIE MOWERY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05-4015 BRIAN MOWERY, Defendant CIVIL ACTION - LAW 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 S3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Service by certified mail no. 70001530 0001 6001 9067 on August II, 2005. See attached Affidavit of Service. 3. Date of execution of the Affidavit of Consent required by S3301(c) of the Divorce Code: by the Plaintiff: 1/2412006; by the Defendant: 1/20/2006. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in S3301(c) divorce was filed with the prothonotary: filed simultaneously with this Praecipe to Transmit Record. Date Defendant's Waiver of Notice in S3301(c) divorce was filed with the prothonotary: filed simultaneously with this Praecipe to Transmit Record. RESPECTFULLY SUBMITTED: BY: ~~ ----- Jeanne B. Costopoulos, Esquire ATTORNEY FOR PLAINTIFF 3803 Gettysburg Road Camp Hill, PA 17011 Phone: (717) 920-2500 P A Supreme Ct. ID No. 68735 DATE: 1;;>/201'; ----~------------._~ ..- g ,...., "'" ~ = <:""'" cT" -o'~ <- ~ mt:-) [r ~ rn~ 2. .:~, -Z}" N -0 ' <Zt~. -' ::J~ t,21::...t ~:.~ -) _.~~Ti: ?C~ -0 ;;::s:I3 '''-C ::it 2':0 $oc. - orfi Z -\ ~ - ~ (f\ --'" .--~------ ~~~~~~~~~~~~~~~~~~~T.~~~T.~~~~~~~~~~T.~~~~~~~~~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~~T~TTT~~~TT~~ T~~~TT~~~~ ~TTT.TT~~~T.~+T~TT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . "';t:'f~'fT~~~~ ~~+TT.~T.~~~+~~;!i . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF LAURIE MOWERY, Plaintiff VERSUS BRIAN MOWERY, Defendant PENNA. NO. 05-4015 DECREE IN DIVORCE AND NOW, J2nu'U 1 ~ I LAURIE MOWERY DECREED THAT AND BRIAN MOWERY , 2c(J~, IT IS ORDERED AND , PLAINTIFF, DEFENDANT, A~~E DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOL.LOWING CLAIMS WHICH HAVE YET BEEN ENTERED; None. BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT .. .. T+'f+~;+'T.;+' +~;+'T;+' ~;+''''T;+'~~T;+'~ .. ~9- /' J. PROTHONOTARY ;# ~ I'fT'Pff "y11,!1l' I f ,{ . .' /J.' #[ .,f / e ~ FJ'?ff'" _v r , I .