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Home My WebLink About06-1338 HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29820 84 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-8080 ATTORNEY FOR PLAINTIFF Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA MARK ... DePUE, v. = CIVILACTION_-;~W = NO. 2006 - .a?d:::.CIVIL TERM SUSAN C. DePUE, . . Defendant = IN DIVORCE 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 in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, Cumberland County Courthouse, Carlisle, Pennsylvania 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, Pennsylvania 17013 717-249-3166 Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA MARK .J. DePUE, Y. = CIVIL ACTION - LAW = NO. 2006 - /33 f CIVIL TERM SUSAN C. DePUE, Defendant = IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301~ OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is MARK J. DePUE, an adult individual residing in Cumberland County, Pennsylvania, but whose address for the purpose of this litigation is c/o Irwin Law Office, 64 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is SUSAN C. DePUE, an adult individual residing at 621 Todd Court, Lewisberry, York County, Pennsylvania 17339. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on November 8, 1988, in Harrisburg, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. February S5 ,2006 HAROLD S. IRWIN, I Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 : Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA MARK ... DePUE, v. : CIVIL ACTION. LAW : NO. 2006 . /33 f CIVIL TERM SUSAN C. DePUE, Defendant : IN DIVORCE PLAINTIFF"S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. February. 2006 p ~ ;;::J ~ ....{J \l:- ~ \) - -- Ci( ....,) 'i> CY ~ t! :cJ ~1;;F- ~ ~ j-,' ,-, " I 'Q ; '; , , Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA MARK J. DePUE, v. = CIVIL ACTION. LAW = NO. 2006 - 1338 CIVIL TERM SUSAN C. DePUE, . . Defendant = IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 @}{1}ffi NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on March 17, 2006, by certified mail addressed to the defendant at 621 Todd Court, Lewisberry, PA 17339, certified mail No. 7005 182000024619 1828. 3. A copy of the sender's and return receipts are attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, mla"9 10 o",wom fal,';~I;o' 10 aothorille,. /4# IA;JlI.~ . March 20, 2006 " I Harold S. Irwin, III Attorney for plaintiff 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court 10 No. 29920 - 1 co ru co ..... IT" ..... ..II ::r U.S. Postal Service,,, CERTIFIED MAIL,., RECEIPT (Domestic Maif Only; No Insurance Coverage Provided) ru o o D Return Receipt Fee (Endorsement Required) CJ Restricted Delivery Fee ru (Endotsement Required) CO ..... Postmark Ho.. Total Postage & Fees $ U1 o Senr 0 ;2 Si';;.i,'AP;:~---c;:._~~~nn___...__n..._--.- O~~".~_~O:__!e?".~___:::t:~.~.....m__...____________n City.S,.,..Z .\>A \ '~ . Complete items 1, 2, and 3. Also complete Item 4 ~ 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 mail piece, or on the front if space permits. 1. Article Addressed to: D. Is delivery address different from rtem 1? ~ If YES, enter delivery address below: ~o SUSAN C DBPUB 621 TODD CT LEWISBERRY PA 17339 3. Service Type J:L. Certified Mail o Registered o Insured Mail o Express Mall o Return Receipt for Merchandise Dc.o,o. 4. Restricted Delivery? (Extra Fee) Ves 2. Article Number (r ransfer from service label PS Form 3811, February 20D4 7005 1820 0002 4619 1828 Domestic Return Receipt 102S9S-Q2.M-1540 EXHIBIT '"An W;.,; -< /:. co ~o __Cl ;l>e: Z =< C) ....., C~ L:~ C..'"" _t-",. -, ;;0 r0 o l)? o 1'-' o -0 ~-n n'F ""Din lJ'? "', . , -;1........ ,~ ,.., . -"1- ,::;':::. ._)\C, .;,',\ .~ MARK .J. DePUE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 2006 -1338 CIVIL TERM SUSAN C. DePUE, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY NOW come the plaintiff, MARK J. DePUE, by his attorneys, Irwin & Bayley, and presents the following complaint for custody, representing as follows: 1. The plaintiff is MARK J. DePUE, an adult individual residing at 46 Brian Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is SUSAN C. DePUE, an adult individual residing at 621 Todd Court, Lewisberry, York County, Pennsylvania 17339. 3. The parties were married on November 8, 1988, but separated on or about January 3, 2006. A divorce complaint was filed to this term and number on March 20, 2006. 4. The parties are the parents of two minor children; namely, TAYLOR C. DePUE (born June 4,1992) and TRISTAN A. DePUE (born April 30, 1995), who have lived primarily with their mother, the defendant, since the parties separation. 5. 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. " 6. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. 7. 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. 8. The best interests and permanent welfare of the children require that the parties have joint legal custody of the children, but that the plaintiff have primary physical custody, subject to periods of partial physical custody with the defendant. WHEREFORE, the plaintiffs request that the court enter an order providing for the legal and physical custody of the children as aforesaid. May 12, 2006 64 South Pitt Street Carlisle, Pennsylvania 17013-3220 (717) 243-6090 Supreme Court I.D. No. 29920 VERIFICATION I do hereby verify that the facts set forth in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~4904, relating to unsworn falsification to authorities, May 12, 2006 ':\{ ..lQ..J-, MARK J. De~E r::='\~D ~ f\.- ~ ~~~ ...... v~-.J d,~~ ~ () ~ ..C,~._ -0 i'l , 'II:, 7 (j) ~'--, r~ ~; ~,~~ ,,"=, ( J :PC --, ~ ,..:> = = <::r' ::1t ::P'" -< .. co -C ::: ~ w ~ ~ ..... ~-n I' . F" ~fTl :(j9 qC) ~"~"\ .-;:" :r: '-l~\. (~O .t:-rn 9 ~ MARK J. DEPUE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. 06-1338 CIVIL ACTION LAW SUSAN C. CEPUE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, May 26, 2006 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 27, 2006 at 9:30 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. 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 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 hearin2:. FOR THE COURT. By: Isl Tacqueline M. Vemey, Esq. Custody Conciliator ~ -- The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Oisabilites 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 HA VE 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 '~~I?-F ~~~,?r/ ~ 'W.o<~ .~~ ~rVW ~ ?2-l7C'...> ~p ~ "t'~ ~ . ro/ '?t:7.c7E-,S' " ,IX::::\Ji\~jd \if'.!f"')t.....'"-., ....,- I I ..t.I\', ,',' ' ':+,!f\lno L S :2 ~~d 08 A VW 9DOZ AtlV10NUiLOdd 3/-f1::f0 38Ij~O-0311,j DEe IS 2fBy( MARK J. DEPUE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2006-1338 CIVIL ACTION - LAW SUSAN C. DEPUE, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 15th day of December, 2006, the Conciliator being notified that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~.~ onciliator \/i j\J \:;/\-l},~s\;r'.J.jd )J' '{1""/" '-""""na . r\r ~ ~;I .' " """'"'j'\1I . ~ ",' : ..Ii 'I! 28 :8 Wd 9 I :)30900l 'Ll\.Jl(V ." " <'" I I 3Hl .:\0 Aov, vi\~u,'~Jl)CjtJ I ' 301:!~{}-(131!:l