HomeMy WebLinkAbout87-0035o~
OF
CUMBERLAND COUNTY, PENNA.
CIVIL ACTION - LAW
NO. 3~ 1987
DEANNA E. LUCKENBAUGH,
Plaintiff
EDWARD LUCKENBAUGH,
Defendant
ORDER
WlDOFF, REAGER,
SELKOWlTZ & ADLER, P.C.
ATTORNEYS AT LAW
P. O. BOX 1547
HARRISBURG, PA 17105
(717) 234-1383
DEANNA E. LUCKENBAUGH
Plaintiff
VS.
EDWARD LUCKENBAUGH
Defendant
In the Court ot Common Pleas o~
Cumberland County, Penmylvan~
No. 35 CN~. 87
19 ......
PRAECIPE FOR EN.T__R.Y._Q_F___A_P..P.E..A._R~__N_C.E
Please enter my appearance in the above_-.~_p, tioned__o, matter.
March 6
Prothonotary
127 State St.
Harrisburg, Pt 17101
¢717) 234-1383
DEANNA E. LUCKENBAUGH
EDWARD LUCKENBAUGH
PRAE(]IPE
Filed ........................... 19_ ......
.................................. , Att),.
DEANNA E. LUCKENBAUGH,
Plaintiff
VS.
EDWARD LUCKENBAUGH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
CIVIL ACTION - LAW
ORDER
YOU, EDWARD LUCKENBAUGH, DEFENDANT, HAVE BEEN SUED IN
COURT TO OBTAIN VISITATION OF THE FOLLOWING CHILD: DANIELLE
MARIE LUCKENBAUGH.
You are ordered to appear in person at the Cumberland
County Courthouse, Carlisle, Pennsylvania on the ~7~ day
of.~~-~ , 198~, at /'c~c) o'clock, _~_.m., for a
hearing~ ~ ~-,~ ~t 3.
You are further ordered to bring with you the said
child: DANIELLE MARIE LUCKENBAUGH
If you fail to appear as provided by this Order or to
bring the child, an order for visitation may be entered
against you or the court may issue a warrant for your
arrest.
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.
Dated:
Court Administrator
Cumberland County Courthouse
South Hanover Street
Carlisle, PA 17013
(717) 697-1133
BY THE COURT.'
Je
-2-
IN THE COURT OF COMMON PL
OF
CUMBERLAND COUNTY, PENNA.
CIVIL ACTION - LAW
NO. 35' 1987
DEANNA E. LUCKENBAUGH,
Plaintiff
V.
EDWARD LUCKENBAUGH,
Defendant
PETITION FOR VISITATION
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
P. O. BOX 1547
HARRISBURG, PA 17105
(717) 234-1383
OF THE F[~OI.qONO?~R¥
0UN ~ ~!~[. ~,N~] COUNTY
[~E ~ ~ SYLVANiA
DEANNA E. LUCKENBAUGH,
Petitioner
VS.
EDWARD LUCKENBAUGH,
Respondent
· ' IN THE COURT OF COMMON PLEAS
· ' CUMBERLAND COUNTY, PENNA.
· ' NO. _35 TERM 1987
: CIVIL ACTION-LAW
PETITION FOR VISITATION
TO THE HONORABLE, THE JUDGES OF SAID COURT:
1. Petitioner is DEANNA E. LUCKENBAUGH, who resides at
5 North Arch Street, Mechanicsburg, Cumberland County,
Pennsylvania.
2. Respondent is EDWARD LUCKENBAUGH, who resides at
15 East Lisburn Road, Bowmansdale, Cumberland County,
Pennsylvania.
3. Petitioner and Respondent were married on September
18, 1971 in Altoona, Pennsylvania, and were separated on
January 2, 1986.
4. Three (3) children were born of the marriage, said
children being Danielle Marie, born November 2, 1973; Betsy
Ann, born April 11, 1976; and Herman Charles, born January
18, 1979.
5. Since the separation of the parties, the minor
children were initially in the custody of Petitioner. Since
August 30, 1986, Danielle Marie has been in the custody of
Respondent.
6. The best interests and welfare of Danielle require
that she have a relationship with both parents and, to that
end, she should be permitted to visit with Petitioner.
7. Petitioner has been denied the right of adequate
and proper visitation with the child, Danielle Marie, in
that: Respondent, without explanation, has refused to allow
Petitioner to see Danielle since December 2, 1986 except for
one half hour on December 21, 1986, and has refused to discuss
his reasons for that refusal.
8. Petitioner has adequate facilities and the ability
to provide for the physical needs and comfort of the child
during visitation.
9. The present address of the minor children is
Pennsylvania.
10. The minor children have resided at the following
places during the past five years:
Box lA, Portage, Pennsylvania 15946;
202 North Frederick Street, Mechanicsburg, Pennsylvania 17055;
209 East Locust Street, Mechanicsburg, Pennsylvania 17055;
5 North Arch Street, Mechanicsburg, Pennsylvania 17055.
11. The names and present addresses of the persons with
whom the minor children have lived during the past five
years are: Deanna and Edward Luckenbaugh. See addresses in
response to #10 above.
12. Petitioner has not participated as a party,
witness, or otherwise in any other litigation concerning the
custody of the said children in Pennsylvania or any other
state.
13. Petitioner does not have information of any custody
proceeding concerning the said children in any court of
Pennsylvania or any other state.
14. Petitioner does not know of any person not a party
to these proceedings who has physical custody of the said
children or who claims to have custody or visitation rights
with respect to them.
WHEREFORE, Petitioner respectfully prays Your Honorable
Court to grant visitation with the minor child, Danielle
Marie, as follows: with Deanna Luckenbaugh, Petitioner,
every other weekend from Friday evening to Sunday evening,
-3-
and alternating holidays, or such other visitation as the
Court may deem appropriate.
Dated: January 7, 1987
Respectfully submitted,
WIDOFF, REAGER, SELKOWITZ
larry B. Selkowitz, Esqu~
127 State Street
Harrisburg, PA 17101
Attorneys for Petitioner
-4_
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
)
: SS:
DEANNA E. LUCKENBAUGH, being duly sworn according to
law, deposes and says that she is the Petitioner in the
foregoing Petition for Visitation and that the facts set forth
are true and correct to the best of her knowledge, information
and belief.
- Deanna ~, L~c~
Sworn to and subscribed
before me this /~ day
of ~,~,~=~_ , 1986.
My Commission Expires:
M~CHANIC~URG ~C~O, CU~LAND CO~N~
MY COMMISSION EXPIRES MAY 30,
M~ber, Penflsytvafl~ Association of Notates
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
IARRISBURG, PENNSYLVANU
17101
(717) 234-1383
CERTIFICATE OF SERVICE
I hereby certify that I caused a true and correct copy of
the foregoing Petition for Visitation, to be placed in the
United States Mail, first class, postage prepaid, to the person
listed below:
Edward Luckenbaugh
15 East Lisburn Road
Bowmansdale, PA 17008
Dated: January 7, 1986
IN THE COURT OF COMMON PLEAS
OF
CUMBERLAND COUNTY, PENNA.
CIVIL ACTION - LAW
NO. 35 CIVIL 1987
DEANNA E. LUCKENBAUGH,
Plaintiff
EDWARD LUCKENBAUGH,
Defendant
AMENDED PETITION-COMPLAINT
FOR CUSTODY
WIDOFF, REAGER,
SELKOWITZ &ADLER, P.C.
ATTORNEYS AT LAW
P. O. BOX 1547
HARRISBURG, PA17105
(717) 234-1383
M~, 9 3 sD DM'8'~
DEANNA E. LUCKENBAUGH,
Plaintiff
V.
EDWARD LUCKENBAUGH,
Defendant
: IN THE COURT OF COMMON PLEAS
· ' OF
:CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 35 CIVIL 1987
· ' IN DIVORCE
.ORDER
YOU, EDWARD LUCKENBAUGH, DEFENDANT, HAVE BEEN SUED IN
COURT TO OBTAIN CUSTODY OF THE FOLLOWING CHILD: DANIELLE MARIE
LUCKENBAUGH.
You are ordered to appear in person at the Cumberland
County Courthouse, Carlisle, Pennsylvania on the 20th day of
March, 1987, at 1:30 o'clock, p.m., for a hearing, as
previously scheduled on the Petition for Visitation.
You are further ordered to bring with you the said
child: DANIELLE MARIE LUCKENBAUGH.
If you fail to appear as provided by this Order or to
bring the child, an order for custody may be entered against
you or the court may issue a warrant for your arrest.
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
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.
COURT ADMINISTRATOR
THIRD FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 249-1133
Dated:
BY THE COURT:
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
DEANNA E. LUCKENBAUGH,
Plaintiff
Ve
EDWARD LUCKENBAUGH,
Defendant
: IN THE COURT OF COMMON PLEAS
: OF
:CUMBERLAND COUNTY, PENNSYLVANIA
· ' CIVIL ACTION - LAW
: NO. 35 CIVIL 1987
:
: IN DIVORCE
AMENDED PETITION -COMPLAINT FOR CUSTODY
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
Plaintiff, Deanna Luckenbaugh, through her attorneys,
Laurie Juengert and Larry B. Selkowitz, hereby amend the
Petition for Visitation filed on January 8, 1987 to ask this
Court to award permanent custody of Danielle Marie Luckenbaugh
to Plaintiff well as custody of Herman Charles and Betsy
Anne, who currentiy reside with Plaintiff. As grounds and
reasons, therefore, Plaintiff states as follows:
1. Plaintiff incorporates herein by reference
paragraphs 1-14 of her Petition for Visitation.
2. On or about March 1, 1987 Plaintiff was informed
by Defendant of his intention to move to Portage, Pennsylvania
in April or sooner and of his intention to take Danielle Marie
with him.
3. Plaintiff asked Defendant to at least permit
Danielle to finish school in this area before moving her to
Portage.
4. Defendant refused to negotiate on this issue and
in fact, removed Danielle from school on or about Thursday,
March 5, 1987 and moved her to Portage, Pennsylvania against
Piaintiff's wishes and without notifying Piaintiff of his
intention to do so.
5. Plaintiff believes it is not in the minor child's
best interest to be moved away from Plaintiff and from her
younger brother and sister.
6. Plaintiff believes it is in the best interest of
Danielle Marie, Herman Charles and Betsy Ann that Plaintiff be
awarded permanent custody with liberal and reasonable
visitation permitted with Defendant.
WHEREFORE, Plaintiff asks this Honorable Court to
award permanent custody of Danielle Marie, Herman Charles and
Betsy Ann to Deanna Luckenbaugh.
Respectfully submitted,
WIDOFF, REAGER, SELKOWITZ & ADLER, P.C.
L~u~ie Juengert/,~ ~squi~e
Attorney for P~intif~/
127 State Street
P. O. Box 1547
Harrisburg, PA 17105
(717) 234-1383
Dated: March 9, 1987
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
VERIFICATION
The undersigned verifies that the answers contained
herein are true and correct. The undersigned understands that
false statements herein are made subject to the penalties of 18
Pa. C.S. Section 4904, relating to unsworn falsification to
authorities.
~'~anna E. LUcke~b~ugh ~-
Dated: March 6, 1987
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
IARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
IN THE COURT OF COMMON
PLEAS, CUMBERLAND COUNTY,
PENNSYLVANIA
NO. TERM 1986
IN DIVORCE
DEANNA E. LUCKENBAUGH,
Plaintiff
vs.
EDWARD LUCKENBAUGH,
Defendant
AFFIDAVIT OF SERVICE OF
DIVORCE COMPLAINT
WlDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
129 STATE STREET
HARRISBURG, PENNSYLVANIA 17101
(717) 234-1383
J~, Zr] I s~ PH
DEANNA E. LUCKENBAUGH,
Plaintiff
vs.
EDWARD LUCKENBAUGH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
NO. 35 CIVIL 1987
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNA. :
COUNTY OF DAUPHIN
I, LARRY B. SELKOWITZ, Esquire, hereby certify that I
served a true and correct copy of the Complaint in Divorce
upon the Defendant, EDWARD LUCKENBAUGH, on January 9
1987, addressed to 15 East Lisburn Road, Bowmansdale,
Pennsylvania, 17008, by Certified Mail #041 296 809, as
evidenced by the original return receipt attached hereto.
Sworn to and subscribed
befo32e me this /~ day
of (~.~~ , 198 7.
N OTA R____Y PU..BLI C
My Commission Expires:
WIDOFF, REAGER, SELKOWITZ
& ADLER, P.C.
L~fry B{ Selkow-ifz; EsquireS)_
127 State Street
Harrisburg, PA 17101
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
OF
CUMBERLAND COUNTY, PENNA.
CIVIL ACTION - LAW
NO. 1987
DEANNA E. LUCKENBAUGH,
Plaintiff
EDWARD LUCKENBAUGH,
Defendant
PRAECIPE TO PROCEED IN
FORMA PAUPERIS
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
P. O. BOX 1547
HARRISBURG, PA 17105
(717) 234-1383
DEANNA E. LUCKENBAUGH,
Plaintiff
V.
EDWARD LUCKENBAUGH,
Defendant
: IN THE COURT OF COMMON PLEAS
· ' OF
:CUMBERLAND COUNTY, PENNSYLVANIA
· ' CIVIL ACTION - LAW
: NO.~.~- ~C~ 1987
IN DIVORCE
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Deanna E. Luckenbaugh, Plaintiff, to proceed
in forma pauperis:
I, Larry B. Selkowitz, attorney for the party proceeding
in forma pauperis, certify that I believe the party is unable
to pay the costs and that I am providing free legal service to
the party. The party's affidavit showing inability to pay the
costs of litigation is attached hereto.
By:
Respectfully submitted,
WID F REA R ,SELKOWITZ & ADLER,
Larry B. Selk~
127 State Street
Harrisburg, PA 17101
PC
DATED: January 7, 1987
WIDOFF, REAGER,
SELKOWlTZ & ADLER, P.C,
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG. PENNSYLVANIA
17101
(717) 234-1383
DEANNA E. LUCKENBAUGH,
Plaintiff
V.
EDWARD LUCKENBAUGH,
Defendant
· ' IN THE COURT OF COMMON PLEAS
: OF
· 'CUMBERLAND COUNTY, PENNSYLVANIA
· ' CIVIL ACTION - LAW
: NO. 198?
:
· ' IN DIVORCE
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I am the Plaintiff in the above matter and because of
my financial condition am unable to pay the fees and costs of
prosecuting or defending the action or proceeding.
2. I am unable to obtain funds from anyone, including my
family and associates, to pay the costs of litigation.
3. I represent that the information below relating to my
ability to pay the fees and costs is true and correct:
(a) Name: Deanna E. Luckenbaugh
Address: 5 North Arch Street, Mechanicsburg, PA
Social Security Number: 172-36-6273
(b) Employment:
Employer: Seidle Memorial Hospital, Mechanicsburg, PA
Address: 120 South Filbert Street, Mechanicsburg, PA
Salary or wages per month: $503.72
Type of work: Housekeeping
(c) Other income within the past twelve months: $70.00/week
in support from Husband
(d) Other contributions to household support:
Name: Edward Luckenbaugh
(e)
Motor vehicle:
Stocks; bonds:
Other: None
Employer: New Cumberland Army Depot
Salary or wages per month: Unknown
Type of work: Forklift Operator
Property owned:
Cash: $25.00
Checking account: $50.00
Savings account: $5.00
Certificates of deposit: None
Real estate (including home): None
None
None
(f) Debts and obligations:
Mortgage: None
Rent: $420.00 plus $165.00 utilities
Loans: None
Other: Food, $200/month; insurance, $15.00/month; medical
expenses, $45.00/month
(g) Persons dependent upon you for support:
Children, if any:
Name: Betsy Ann 10
Herman Charles 7
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717} 234-1383
-2-
4. I understand that I have a continuing obligation to
inform the court of improvement in my financial circumstances
which would permit me to pay the costs incurred herein.
5. 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.
Dated ..
~u~kenbi~
-4-
THE COURT OF COMMON PLEAS
OF
CUMBERLAND COUNTY, PENNA.
CIVIL ~CTIO~ - LAW
NO. ~ )~ 1987
DEANNA E.
LUCKENBAUGH,
Plaintif
v.
EDWARD LUCKENBAUGH,
Defendar
COMPLAINT IN DIVORCE
WlDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
P. O. BOX 1547
HARRISBURG, PA 17105
(717) 234-1383
DEANNA E. LUCKENBAUGH,
Plaintiff
EDWARD LUCKENBAUGH,
Defendant
: IN THE COURT OF COMMON PLEAS
· ' OF
:CUMBERLAND COUNTY, PENNSYLVANIA
· ' CIVIL ACTION - LAW
: NO, 3 >'~ ~/~,~ 198~
:
: IN DIVORCE
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 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.
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 Dauphin
County Court House, Harrisburg, Pa 17101.
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
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
{717) 234-1383
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
COURT ADMINISTRATOR
THIRD FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 249-1133
Respectfully submitted,
By:
WIDOFF, REAGER, SELKOWITZ & ADLER, P.C.
Attorney for Plaintiff
127 State Street
P. O. Box 1547
Harrisburg, PA 17105
(717) 234-1383
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
DEANNA E. LUCKENBAUGH,
Plaintiff
V.
EDWARD LUCKENBAUGH,
Defendant
.' IN THE COURT OF COMMON PLEAS
· ' OF
:CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL AC~]~ON - LAW
: NO. Z,f ~J 1987
:
: IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 201(c) OF THE DIVORCE CODE
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
1. The Plaintiff, Deanna E. Luckenbaugh, is an adult
individual residing at 209 E. Locust Street, Mechanicsburg,
Cumberland County, Pennsylvania since July 1, 1986.
2. The Defendant, Edward Luckenbaugh, is an adult
individual residing at 15 East Lisburn Road, Bowmansdale,
Cumberland County, Pennsylvania since January 2, 1986.
3. Both the Plaintiff and Defendant are bona fide
residents of the Commonwealth of Pennsylvania for at least six
(6) months prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on September
18, 1971, at Altoona, Blair County, Pennsylvania.
5. There are three (3) children born of this marriage:
Danielle Marie Luckenbaugh, born November 2, 1973, Betsy Ann
Luckenbaugh, born April 11, 1976, and Herman Charles
Luckenbaugh, born January 18, 1979. Betsy Ann and Herman
Charles currently reside with Plaintiff at 5 North Arch Street,
Mechanicsburg, Pennsylvania. Danielle Marie currently resides
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
with the Defendant at 15 East Lisburn Road, Bowmansdale,
Pennsylvania.
6. This action is not collusive.
7. There have been no prior actions or divorce or
annulment between the parties in this or any other
jurisdiction.
8. The Defendant is not a member of the armed services of
the United States of America or any of its allies.
9. The Plaintiff avers as the grounds on which this
action is based that the marriage is irretrievably broken in
accordance with Section 201(c) of the Divorce Code of 1980.
10. Plaintiff has been advised as to the availability of
counseling and may have the right to request that the court
require the parties to participate in counseling.
WHEREFORE, Plaintiff requests your Honorable Court to
enter a decree:
(a) dissolving the marriage between Plaintiff and
Defendant; and
(b) for such further relief as the Court may deem
equitable and just.
COUNT II: INDIGNITIES
11. The allegations contained in Paragraphs 1 through 10
inclusive herein are incorporated by reference hereto as fully
as though the same were set forth at length.
12. The Plaintiff is the injured and innocent spouse.
-2-
WIDOFF, REAGER,
SELKOWITZ &ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 23~1383
13. That in violation of the marriage vows, the Defendant
has offered such indignities to the person of the Plaintiff as
to render her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests your Honorable Court to
enter a decree divorcing the Plaintiff from the bonds of
matrimony heretofore existing between the Plaintiff and
Defendant.
COUNT III: ALIMONY
14. The allegations contained in Paragraph 1 through 13
inclusive herein are incorporated by reference hereto as fully
as though the same were set forth at length.
15. Plaintiff lacks sufficient property to provide for her
reasonable means, and is unable to support herself through
existing employment.
16. Plaintiff requires reasonable support to adequately
maintain herself in accordance with the standard of living
established during the marriage.
WHEREFORE, Plaintiff requests your Honorable Court to enter
an award of alimony.
COUNT IV. CUSTODY
17. The allegations contained in Paragraph 1-16 inclusive
herein are incorporated by reference hereto as fully as though
the same were set forth at length.
18. Plaintiff requests custody of two of the minor
children of the marriage, Betsy Ann, age 10 and Herman Charles,
-3-
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
age 7, who currently reside with Plaintiff. Plaintiff also
requests liberal and reasonable visitation with Danielle Marie,
age 12, currently residing with Defendant.
WHEREFORE, Plaintiff requests your Honorable Court to grant
her custody of Betsy Ann and Herman Charles and liberal
visitation with Danielle Marie.
COUNT V: CHILD SUPPORT
19. The allegations contained in Paragraphs 1-18 inclusive
herein are incorporated by reference hereto as fully as though
the same were set forth at length.
20. Plaintiff has been receiving $70.00 per week of
support pursuant to order of this Court No. 108 of 1986, dated
August 12, 1986, and wishes to have Defendant continue to pay
such support.
WHEREFORE, Plaintiff requests your Honorable Court to enter
a child support award.
By:
Respectfully submitted,
WIDOFF REAGER SELKOWITZ & ADLER, PC
127 State Street
Harrisburg, PA 17101
DATED: January 7, 1987
-4-
VERIFICATION
The undersigned verifies that the answers contained
herein are true and correct. The undersigned understands that
false statements herein are made subject to the penalties of 18
Pa. C.S. Section 4904, relating to unsworn falsification to
authorities.
· · Luckenbaugh ~
Dated:
DEANNA E. LUCKENBAUGH,
Plaintiff
EDWARD LUCKENBAUGH,
Defendant
: IN THE COURT OF COMMON PLEAS
: OF
:CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 35 CIVIL 1987
:
: IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
:
COUNTY OF DAUPHIN
SS:
I, WALTER JUNKINS, hereby certify that I personally served
a true and correct copy of the Petition for Visitation and the
Amended Petition-Complaint for Custody upon the Defendant,
EDWARD LUCKENBAUGH, on March 10, 1987 at 1:55 p.m. at his work-
place, the United States Army Depot, New Cumberland, Penn-
sylvania.
Walter Junkins
Sworn to and subscribed before me
this I~~- day of March, 1987.
WIDOFF, REAGER,
SELKOWITZ & ADLER, P.C.
ATTORNEYS AT LAW
127 STATE STREET
HARRISBURG, PENNSYLVANIA
17101
(717) 234-1383
Notary Publi~J
My Cor~nission Expires:
LISA M. MATJASIC, NOTARY PUBLIC
HARRt$SUi~G, DAUPHIN COUNTY
MY ~O~Ni!$~ION £~P?;~S JUN~ 4, 1990
Mlmbl~, P~'lva~a A~5~c~o,,~ of Notaries
DEANNA E. LUCKENBAUGH,
Plaintiff
Ve
EDWARD LUCKENBAUGH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 35 CIVIL 1987
IN DIVORCE
IN RE: CUSTODY
ORDER OF COURT
AND NOW, March 20, 1987, the parties having appeared
with counsel and having come to an agreement with respect to the
three minor children, Danielle Marie Luckenbaugh, born November
2, 1973, Betsy Anne Luckenbaugh, born April 11, 1976, and Herman
Charles Luckenbaugh, born January 18, 1979, it is ordered and
directed as follows:
1. Primary physical custody of Danielle Marie
Luckenbaugh shall be and remain in the natural father, Edward
Luckenbaugh.
2. Primary physical custody of Betsy Anne Luckenbaugh
and Herman Charles Luckenbaugh, shall be and remain in the
natural mother, Deanna E. Luckenbaugh.
3. The minor child, Danielle Marie Luckenbaugh, shall
be with her mother for periods of partial custody as follows:
a. One weekend each month with the mother to be
permitted to have her daughter for the Easter weekend during the
month of April. All other weekend periods of partial custody
shall be arranged between the parties considering the respective
schedules of the parties and the child;
b. One month in the summer to begin immediately
following the adjournment of the school term in the district
where the mother is living;
c. Alternating the day school adjourns for the
Christmas holiday through December 26 and December 26 through
January 1.
4. Both parents are directed to keep the other
informed of each child's progress in school, each child's medical
needs, and to consult with the other parent regarding any other
major decisions affecting each child.
5. The father shall have rights of partial custody
with Betsy Anne Luckenbaugh and Herman Charles Luckenbaugh at
such times the parties can mutually agree.
Laurie Juengert, Esquire
For the Plaintiff
E. Robert Elicker II, Esquire
For the Defendant
By the Court,