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Home My WebLink About06-3576 . -'\ c, v HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29820 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF BRANDON L. FARENCE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . v. : CIVIL ACTION. LA~ : NO. 2006. 'J;.IJ1 CIVIL TERM .JULIE R. FARENCE, 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 " .' BRANDON L. FARENCE, Plaintiff : IN THE COURT OF COMMON PLUS OF : CUMBERLAND COUNTY, PENNSYLVANIA Y. : CIVIL ACTION. LAW : NO. 2008 .M?{, CIVIL TERM .lULIE R. FARENCE, Der.ndant . . : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(g OF THE DIVORCE CODE NOW, comes the plaintiff, by his attomey, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is BRANDON L. FARENCE, an adult individual residing at 46 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The defendant is JULIE R. FARENCE, an adult individual residing at 2321 South Rockport Road, Bloomington, Indiana 47401. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on July 29, 2004 in Bloomington, Indiana. 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. . r 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 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 unswom falsification to authorities. June 21, 2006 ~.,--~~ BRANDON L. ENCE, Plaintiff HAROLD S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court 10 No. 29920 '. 0' BRANDON L FARENCE, Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA . . Y. I CIVIL ACTION - LAW I NO. 2006 - CIVIL TERM JULIE R. FARENCE, Defendant I 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 unswom falsification to authorities. June 21, 2006 ~..~ ~~;T;A NOON L. F . aintiff '~ ~ 0 ......, rt ~ S:c~ C:) 0 (;;~ 0~i"-' <.:.r.... 'Tl L_ -l ~~~::: :r:..,., ...... ~ .,;....~ In! ~ !'-, fTi N V () ::S -" .....; ,- ~ -- ffi - ~ .:;i 01 c:: <ig BRANDON L. FARENCE, Plaint.., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . Y. : CIVIL ACTION - LAW : NO. 2006 - ~?hCIVIL TERM .lUUE R. FARENCE, Defendant . . : IN CUSTODY COMPLAINT FOR CUSTODY NOW corne the plaintiff, BRANDON L. FARENCE, by his attorneys, Irwin & Bayley, and presents the following complaint for custody, representing as follows: 1. The plaintiff is BRANDON L. FARENCE, an adult individual residing at 46 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The defendant is JULIE R. FARENCE, an adult individual residing at 2321 South Rockport Road, Bloomington, Indiana 47401. 3. The parties were married on July 29, 2004, but separated in April, 2005. 4. The parties are the natural parents of two children, namely, BRANDON JOSEPH FARENCE (born February 6, 2003, age 3 years) and CHASTIN MACADE FARENCE (born December 4,2004, age 1 year). 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, that the plaintiff have primary physical custody of BRANDON JOSEPH FARENCE, that the defendant have primary physical custody of CHASTIN MACADE FARENCE, and that both parties have scheduled periods of partial custody with the child for whom they are not the primary custodial parent. WHEREFORE, the plaintiffs request that the court enter an order providing for the legal and physical custody of the children as aforesaid. HAROLD 5. IRWIN, III Attorney for Plaintiff June 21, 2006 64 South Pitt Street Carlisle, Pennsylvania 17013-3220 (717) 243-6090 Supreme Court 1.0. 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. June 21, 2006 -(j._~./~ ~. - ~ - BRANDON L. FA~E E :'''" coo, l'""") ~;,j~~ -n ~~~ ~ -'---J "" ..i ~ - ...... . '^ c:;,!., ~ . c~ :-l ;::;1: " 111C::' c- l ~. \ ;--..., N ~ {'.,) ,. ~ -);:<1 , ~D -< C h, \ BRANDON L. FARENCE PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 06-3576 CIVIL ACTION LA W JULIE R. F ARENCE DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, June 27, 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 Couuty Courthouse, Carlisle on Thursday, July 20, 2006 at 10:30 AM for a Pre-Hearing Custody Conference. At sllch 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 mav also be present at the conference. Failure to appear at the conference mav 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 hearin\!. FOR THE COURT, By: Isl facqueline M. Vemev. Esq..MI<! 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 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 _ # ~~".~ IP' ~ t'''.7'fr/ ~ -tlP.7 ~'-' ~ ~ jp:t ~~ ~-PfJ " \ n'"':: \ Z ""'-, .,.l"'" \.\ c,..\l. "kJ' 0[-'1 'JI' . Q["-'7 ')r? ocr? . O~"FlvrcD "J" I) t, ',rrl :\ ,." ,\ b . "C" I' .. BRANDON L. FARENCE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-3576 CIVIL ACTION - LAW JULIE R. FARENCE, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of W- ,2006, upon eonsideration of the attached Custody Conciliation Report, it is ordered and directed as follows: I. The Custody Complaint in the above captioned matter is hereby withdrawn. 2. 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. 1. c~arold S. Irwin, III, Esquire, Counsel for Fathe' v1Ulie Farence Dugger, pro se, 2321 South Rockport Road ~ Bloomington, Indiana 47401 k-,OV ~V- \J VlNVAlASNN3d AlNflo:J GtH1H3800a .~' ~ .' OS III Wd g- SOV 90l)l A!:l\fl0N0HJ.Ol::kl 3H! :lO 3:)l:Jjo-cEl1l:l 'tl'" . <:r:~.,( , , ... , ,~/ " ". . BRANDON L. FARENCE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : 2006-3576 CIVIL ACTION - LAW JULIE R. FARENCE, Defendant : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Children who are the subjeet of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Brandon Joseph Farence Chastin Maeade Farence February 6, 2003 Father December 4, 2004 Mother 2, A Conciliation Conference was held in this matter on August 3, 2006, with the following individuals in attendance: The Father, Brandon 1. Farenee, with his counsel, Harold S. Irwin, III, Esquire and the Mother, Julie R. Farence, pro se, by telephone from Bloomington, Indiana. 3. The parties confirmed that the ehild has only been in the jurisdiction of Pennsylvania since February 17,2006, less than six months. Father's counsel requested his complaint be withdrawn. 4. The parties agreed to the entry of an Order in the form as attached. r-y-o" Date ~~;~ Custody Conciliator