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SINON WILLIAN BARBUSH, JR. I IN THE COURT OF COMMON PLEAS
Petitioner I CUMBERLAND COUNTY, PENNSYLVANIA
I
v. I No.
I
HELEN BARBUSH I CIVIL ACTION LAW - CUSTODY
Respondent I
TO THB II01fORABLB JUDGB or SAID COUR'l':
BllBRGBNCY PBTITIONBR POR HODIPICATIOII
or CUSTODY ORDBR
AND NOW, comes Petitioner, SiIMJn "iUiu Barbuah, Jr., through
his attorney, Lawrence J. Rosen, Esquire, and otters the tollowing
fact. in support ot the instant'Petition:
"
1. 'Petitioner, simon William Barbush, Jr., as a forty-one year
old male, residing at 307 W. D~uphin street, Enola, PA 17025.
, .;
2. Respondent, Helen Barbush, is a thirty-one year old temale
whose present address'is currently unknown.
3.
Respondent's last known residence was with her Aunt,
at
,
..
5.
Petitioner is a self-employed roofer.
Respondent is not employed at this tille.
The parties were married on August 11, 1987 in Virginia Beach,
Virginia.
6.
7.
There were two (2) children born as a result of this marriage:
1) Jessica Marie Barbush - D.O.B. - July 12, 1984
2) Simon William Barbush, III - D.O.B. March 8, 19Qa~1
"
8.
The parties have been separated as ot December of 1992 when,
without notice, Respondent left the tamily domicile and took
the atorementioned children with her and moved to Kentucky.
9. On November 24, 1993, Respondent tiled a Petition tor
Dissolution of marriage in the 27th Judicial circuit, Laurel
Circuit Court ot the Commonwealth ot Kentucky (Exhibit A).
10. A final hearing on atoresaid Petition tor Dissolution ot
Narriage was held on April 20, 1994 in the state ot Kentucky.
11. Petitioner never received notice of said hearing,
notwithstanding that Respondent and counsel tor Respondent
were tully aware of Petitioner's address (See Exhibit A,
Paragraph 3).
12. By Order dated June 17, 1994 a Decree ot Dissolution ot
Narriage was issued by the Laurel Circuit Court in the State
ot Kentucky (See Exhibit B).
13. Said Order awarded custody ot the parties' minor children to
Respondent.
14. There is no finding in aforesaid Decree that Petitioner
received notice of the final hearing on April 30, 1994.
15. From the date of the parties' separation until July ot 1994,
R,spondent refused to permit Petitioner to see his children
,an,d only permitted him to speak to his children tour times.
, '
16. On or about July 4, 1994, Petitioner brought his children to
Pennsylvania with the consent and approval of Respondent.
17. At the time Petitioner 'picked-up his children in Georgia,
Respondent did not have stable housing and the children were
Sleeping on the furniture ot Respondent's relatives.
18. At the time Petitioner piCked-Up his children in Georgia ,
they were clearly undernourished. It took a period ot nearly
'~wo weeks until they were able to adjust to a normal, healthy
diet.
19. Respondent has attempted to commit suicide in front of her
children by slashing her wrists.
Respondent is
employment and
,assistance.
21. Respondent has a drinking problem which makes it impossible
tor her to maintain stable housing, maintain stable employment
or to provide the proper cara, control and nurturing required
by her children.
unwilling and unable to maintain stable
has been and continues to be on public'
20.
22. Respondents emotional problema make it impossible tor her to
maintain stable housing, maintain stable employment or to
provide the proper care, control and nurturing required by her
children.
23. The parties children have been subjected to witnessing
Respondent's repeated sexual affairs with a series ot men and
the children have, on occasion, seen their .other naked with
these .en.
24. Upon taking the children to Georgia on or about June ot 1994,
Respondent and her children stayed with Respondent's parents.
While there, the children were subjected to whippings with
willow branch~s, slaps and other physical abuse at the hands
ot their grandparents. The children were locked out ot the
house or several occasions.
25. Petitioner is e selt-employed rooter, who has a stable history
ot employment/earning capecity.
26. Petitioner is the co-owner of the home in which he resides
with his tiancee, Tonia staseman and her six year old son.
27. It 'the children are returned to Respondent they will be place
in jeopardy due to:
a) Their mother's emotional instability;
b) Their mother's alcoholiBm;
c) Their mother's ability to provide stable housing;
d) Their mother's inability to provide adequate care,
control and nurturing.
e) Their mother litestyle which has exposed the children to
graphic display ot'sexuality with a series ot men.
f) Their mother's inability/unwillingness to maintain stable
employment.
28. As ot the date of this Petition, Respondent has not demanded
that the children be returned to her custody, care and
control.
29. The conditions set forth in 42 PSA 5344 (2) and/or (3) and
5249 (b) are present in the matter thereby permitting Your
Honorable Court to IIssume juriSdiction and to grant the
instant Petition to Nodify a Foreign Custody Decree.
30. Petitioner has t ned with this Court concommi tant with the
instant Petition a standard Petitioner for Custody seeking
physical and legal custody of the subject children.
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SINON WILLIAM BARBUSH, JR.
Peti tioner
Respondent
I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I No.
I
I CIVIL ACTION LAW - CUSTODY
:
v.
HELEN BARBUSH
VERIFICATION
I, SINON WILLIAM BARBUS, JR. hereby verify that the
information contained in the foregoing Petition is true and correct
to the best of my knowledge, information and belief. I also
understand that false statements made herein are subject to the
penalties of 18 Pa. C.S. 5 4904, relating to unsworn falsification
to authorities.
DATE:
,
c :)'II~/ (y?I/
<, ") 1
'~' n .>- t J.c( 'u, F., (oCt
SIMON WILLIAM BARBUSH,
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Thomas M, Place, Esquire
Robert E, Rains
Famllv Law Clinic
For Defendant
District Attorney's Office
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SIMON WILLIAM BARBUSH, JR. I IN THE COURT OF COMMON PLEAS
PetitioMr I CUMBERLAND COUNTY, PENNSYLVANIA
I
v. : No.
~
HELEN BARBUSH : CIVIL ACTION LAW - CUSTODY
Respondent
TO THE HONORABLE JUDGE OF SAID COURT:
EMERGENCY PETITIONER FOR MODIFICATION
OF CUSTODY ORDER
AND NOW, comes Petitioner, Simon William Barbush, Jr., through
his attorney, Lawrence J. Rosen, Esquire, and offers the following
facts in support of the instant Petition:
1. Petitioner, simon William Barbush, Jr., as a forty-one year
old male, residing at 307 W. Dauphin Street, Enola, PA 17025.
2. Respondent, Helen Barbush, is a thirty-one year old female
whose present address is currently unknown.
3. Respondent's last known residence was with her Aunt,
at
4. Petitioner is a self-employed roofer.
5. Respondent is not employed at this time.
6. The parties were married on August 11, 1987 in Virginia Beach,
Virginia.
7. There were two (2) children born as a result of this marriage:
1) Jessica Marie Barbush - D.O.B. - July 12, 1984
2) Simon William Barbush, III - D.O.B. March 8, 1993
8. The parties have been separated as of December of 1992 when,
without notice, Respondent left the family domicile and took
the aforementioned children with her and moved to Kentucky.
9. on November 24, 1993, Respondent filed n Petition for
Dissolution of marriage in the 27th Judicial circuit, Laurel
Circuit Court of the Commonwealth of Kentucky (Exhibit A).
10. A final hearing on aforesaid Petition for Dissolution of
Marriage was held on April 20, 1994 in the state of Kentucky.
Petitioner never
notwithstanding that
were fully aware of
paragraph 3).
12. By Order dated June 17, 1994 a Decree of Dissolution of
Marriage was issued by the Laurel Circuit Court in the state
of Kentucky (See Exhibit B).
received notice of said hearing,
Respondent and counsel for Respondent
Peti tioner' s address (See Exhibit A,
11.
13. Said Order awarded custody of the parties' minor children to
Respondent.
14. There is no finding in aforesaid Decree that Petitioner
received notice of the final hearing on April 30, 1994.
15. From the date of the parties' separation until July of 1994,
Respondent refused to permit Petitioner to see his children
and only permitted him to speak to his children four times.
16. On or about July 4, 1994, Petitioner brought his children to
Pennsylvania with the consent and approval of Respondent.
17. At the time Petitioner picked-up his children in Georgia,
Respondent did not have stable housing and the children were
sleeping on the furniture of Respondent's relatives.
18. At the time Petitioner piCked-up his children in Georgia ,
they were clearly undernourished. It took a period of nearly
two weeks until they were able to adjust to a normal, healthy
diet.
19. Respondent has attempted to commit suicide in front of her
children by slashing her wrists.
20.
Respondent is unwilling and unable to maintain
employment and has been and continues to be on
assistance.
stable
public
21. Respondent has a drinking problem which makes it impossible
for her to maintain stable housing, maintain stable employment
or to provide the proper care, control and nurturing required
by her children.
22. Respondents emotional problems make it impossible for her to
maintain stable housing, maintain stable employment or to
provide the proper care, control and nurturing required by her
children.
23. The parties children have been subjected to witnessing
Respondent's repeated sexual affairs with a series of men and
the children have, on occasion, seen their mother naked with
these men.
24. Upon taking the children to Georgia on or about June of 1994,
Respondent and her children stayed with Respondent's parents.
Whi Ie there, the children were sUbjected to whippings with
willow branches, slaps and other physical abuse at the hands
of their grandparents. The children were locked out of the
house or several occasions.
25. Petitioner is a self-employed roofer, who has a stable history
of employment/earning capacity.
26. Petitioner is the co-owner of the home in which he resides
with his fiancee, Tonia Staseman and her six year old son.
27. If the children are returned to Respondent they will be place
in jeopardy due to:
a) Their mother's emotional instability;
b) Their mother's alCOholism;
c) Their mother's ability to provide stable housing;
d) Their mother's inability to provide adequate care,
control and nurturing.
e) Their mother lifestyle which has exposed the children to
graphic display of sexuality with a series of men.
f) Their mother's inability/unwillingness to maintain stable
employment.
28. As of the date of this Petition, Respondent has not demanded
that the children be returned to her custody, care and
control.
29. The conditions set forth in 42 PSA 5344 (2) and/or (3) and
5249 (b) are present in the matter thereby permitting Your
Honorable Court to assume jurisdiction and to grant the
instant Petition to Modify a Foreign Custody Decree.
30. Petitioner has filed with this Court concommitant with the
instant Petition a standard Petitioner fot' Custody seeking
physical and legal custody of the SUbject ahildren.
.......
AJu. q'-l- 4 q 5-"
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COMMONWEALTH OF KENTUCKY
27TH JUDICIAL CIRCUIT
LAUREL CIRCUIT COURT
VIL ACTION NO. 93-CI-699
DIVISION NO. I
HELEN BARBUSH, PETITIONER,
VS. DECREE OF DISSOLUTION OF MARRIAGE
SIMON WILLIAM BARBUSH, JR.,
RESPONDENT.
IN REI
The Ma~~iage of Helen Ba~bush and Simon WilliaM
Ba~bush, Jr., the custody and support of two (2)
infant children.
This Matter caMe on for a final hearing before the Court on
the 20th day of April, 1994. The Petitioner, Helen Barbush, was
present in person and repre.ented by Counsel, WilliaM E. Hensley.
The Re.pondent, Simon William BarblJsh, Jt'., was neither present
in person nor represented by Counsel. The Court, after hearing
testimony of the parties and evidence of the witnesses, makes the
following Findings of Facts and Conclusions of Lawl
FINDINGS OF FACT
1. Petitioner resldes in this state and has been a resident
hereof for 180 days next preceding the filing of this Petition
for Dissolution of Ma~riage.
2. Pet it i':'Yler, Helen BcarblJsh., lS 30 years clf age, she
presently resides at 46 Pine Grove Apartments, Corbin, Kentucky
407011 and she is presently unemployed.
Page 1 of 5 Paqes
3. Respondent, Simon William aarbu.h, Jr., is 43 years of
age, he presently resides at 307 W. Dauphin Street, Enola,
Pennsylvania 17025, and he is presently employed at Stroehman
aaker, Harrisburg, Pennsylvania.
4. Petitioner and Respondent were married on the 11th day
of August, 1987, in Virginia aeach, Virginia, said Marriage
certificate being registered in Virginia Beach, Virginia.
5. Petitioner and Respondent separated on or about December
15, 1992, and have live~ separate and apart since that time.
6. There were two (2) infant children born as a result of
this marriage, namelYI Je.sica Marie aarbush, age nine (9) years,
birthdate being July 12, 19B4, and Simon William aarbush, III,
age siM (6) years, birthdate being March B, 1'3BB. The infant
children reside with the Petitioner.
7. Petitioner states that she ia not now pregnant.
8. There are no marital property nor marital debts for
which the Court is asked to make a diatribution, however, there
is a telephone bill in the amount of '300.00 which the Respondent
should be responsible for.
9. The Petitioner herein has not oarticipated in, ~or has
knowledge of any other proceeding involving the infant children
of the partiea herein pending in this or any other state.
Further, the Petitioner knows of no party to this action who
claims to have custody or viaitation ri~hts with respect to the
lnfant children named herein.
Page 2 of 5 Pages
10. The Petitioner is the fit and proper person to have the
car., cu.tody and control of the infant children, with the
Re.pondent having reasonable rights of visitation which
vi.itation shall be supervised by the Petitioner. In the event
the parties cannot reach an agreement a. to the visitation
arrangement, then in that event, the Respondent will be
responsible to have the Court make the appropriate changes.
11. The Respondent shall pay the Petitioner the Bum of
.173.00 per month a. child support for the parties' infant
children.
12. That the marriage between the Petitioner and Respondent
is irretrievably broken.
CONLUSIONS OF LAW
1. The Court has Jurisdiction of the parties and 0' the
subject matter of this action.
2. The marriage between the parties should be dissolved for
the reason that such is irretrievably broken and Judgment should
be entered accordingly.
3. The Court finds that the best interest of the children
would be served by awarding the custody of the children to the
Petitioner with the Respondent having reasonable rights of
visitation which visitation shall be supervised by the
Petitioner. In the event the parties cannot reach an agreement
as to the visitation arrangement, then ~n that event, the
Respondent will be responsible to have the Court make the
appropriate changes.
P~ge 3 of 5 Pages
4. The Respondent shall pay to the Petitioner the sum of
$173.00 per month for the support of the parties' infant
children.
3. The Respondent shall pay the phone bill in the amount of
$300.00 to Southern eell.
6. The decree should contain a wage .ssignment clause for
any appropriate child support arrearage as mandated pureuant to
KRS 403. 215.
WHEREFORE, IT IS ORDERED, ADJUDGED AND DECREED by the Court
as follows.
1. The marriage previously existing between the Petitioner
and Respondent be and same is hereby dissolved, and each party
is restored to .11 the right. and privileges of an unmarried
person.
a. The Petitioner is awarded tho full care, custody and
control of the partie.' infant children, with the Respondent
having rea.onable rights of visitation which visitation shall be
supervised by the Petitioner. In the event the partie. cannot
rel',ch ay, agreemey,t as to the viliitati.:-n ilrranglfmeYlt, then iYI thilt
event, the Respondent will be responsible to have thlf Court make
the appropriate changes.
3. The Respondent is to pay to the Petitioner the sum of
$173.00 per month as child support for the parties' infant
chi ldrey" this ilme'UYlt is based ,:,n the C'e,r"moYtWealth e,f KeYlt~'cky
Worksheet for Monthly Child Support Obligation.
4. The Respe'Y,dent is t,:, pay the phe'Yle bi 11 iYI the arnount e,f
'3~).OO to Southern Bell.
Page 4 of 5 Pages
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5, Mother removed the children from the area and relocated In Kentucky,
6, Father attempted only minimal contact with the children from December 1992
until July 1994, Despite Mother's invitations to visit the children during this period, Father
declined to do so.
7, Subsequent to a final hearing of Court in Kentucky held on April 20, 1994, which
was attended by Mother and Mother's counsel, William E, Hensley, but not attended by Father
or counsel for Father, the Commonwealth of Kentucky entered a Decree of Dissolution of
Marriage on June 17, 1994, A true and correct copy of said Decree is attached hereto as
Exhibit A and incorporated herein by reference.
8. Said Order of Court awarded Mother primary physical custody of the children and
gave Father reasonable rights of supervised visitation.
9, In May 1994, Mother and children moved from Kentucky to P,O, Box 52
Howard, Georgia.
10. In June 1994, Mother and children moved to 401 Brennan Road, Columbus,
Muskogee County, Georgia.
II, In late June 1994, Mother prepared to move to the place at which she currently
resides, P,O. Box 478, Rankin Street, Cusseta, Chattahoochee County, Georgia.
12. In late June 1994, Mother agreed to allow Father to take the children to
Pennsylvania from July 2, 1994 through August 21, 1994.
13. Father did not return the children to Mother on the agreed upon date of August
21, 1994, just prior to the start of their school year in Georgia.
14, On August 25, 1994, by direction of authorities in Muskogee County, Georgia,
Mother obtained a warrant in Chattahoochee County for the extradition of the children from
Father's residence at 307 West Dauphin Street, Enola, Pennsylvania, to Georgia,
I~, On September 2, 1994, Father l1Ied an Emergency Petition for Modification of
Custody Order,
16, The Uniform Child Custody Jurisdiction Act (UCCJA), 23 Pa,C,S,A, 1 5341 et
seq" governs the court's jurisdiction in this matter, Georgia has adopted the UCCIA, codified
at O,C.G,A, Ul9-9-4Q to 19-9.64,
17, While Kentucky is the children's "home state" pursuant to 23 Pa,C,S,
O~344(a)(l), neither the parties nor the children reside there and Mother does not aver that the
case should be heard in Kentucky,
18, Iurisdiction is proper in Georgia, pursuant to Section 2 of the UCCIA (23 Pa,C,S,
O~344(2)) as it is in the best interests of the children for Georgia to assume jurisdiction because
the children and Mother have a significant connection with Georgia and there is available in
Georgia substantial evidence concerning the present or future care, protection, training and
personal relationships of the children.
19. Iurisdiction is not proper in Pennsylvania pursuant to 23 Pa.C,S, 15344(a)(2) as
the children do not reside in Pennsylvania, but have been here only briefly for a summer visit
and have been wrongfully held over here by the Father,
20, Moreover the allegations in Father's "Emergency Petitioner (sic)", even if true,
do not rise to the level of an emergency, pursuant to 23 Pa.C,S. 005344(a)(3).
21. Iurlsdic.tion is not proper in Pennsylvania pursuant to 23 Pa.C.S. 15349(b) as the
Father's allegations, even if true, do not show conditions in the custodial household sufficiently
harmful to the children 10 warrant the extraordinary remedy of rewarding child snatchlna In the
face of an Order of Court,
22, By kcepina the children in Pennsylvania past the aareed date of return to Georgia,
Auaust21, 1994, Father has acted contrary to 23 Pa,C,S,A, f 5342(a)(5), which intends 10 deter
unilateral removals of children undertaken to obtain custody awards,
23, By issuina a warrant for the extradition of the children from Pennsylvania 10
Georala, the Georgia Court is complying with Georgia's parallel provision to 23 Pa,C,S,A, f
5342(a)(7), facilitation of the enforcement of custody decrees of other stales.
24. Pursuant 10 23 Pa.C,S.A, f 5348, this court may decline jurisdiction If It finds
that it is an inconvenient forum to make a custody determination under the circumstances of the
case and that a court of another state is a more appropriate forum,
25, Mother and children reside In Georgia. Many of Father's allegation's concern
matters that allegedly occurred in Georgia, None of Father's allegations relate to matters or
conditions in Pennsylvania. If, during custody litigation, it is determined that a home study of
Mother is warranted, such study would necessarily occur in Georgia.
26. Moreover, by Father's wrongful withholding of the children in violation of the
current custody Order, he has prevented their timely enrollment in school by the lawful custodial
parent, Exercise of jurisdiction by this court would necessarily cause further delay and
disruption of their education in the county of residence of their custodial parent,
27. Father should not be rewarded for his contumacious conduct to the detriment of
the best interests of the children.
WHEREFORE, the defendant respectfully requests the court to dismiss the plaintiff's
~IJ, IJMl 0( I'ClCIll'd
11I1....L.Lday 0
l~
COMMQNWEALTH OF KENTUCKY
Z7TH JUDICIAL CIRCUIT
LAUREL CIRCUIT COURT
VIL ACTION NO. 93-CI-699
DIVISION NO. I
HELEN BARBUSH,
PETITIONER,
1,16.
DECREE nF DISSOLUTION OF MA~RIAGE
SIMON WILLIAM BARBUSH, JR.,
RESPONDENT.
IN REI
The marriage of Helen Barbush and Simon William
Barbush, Jr., th~ custody and support of two <2>
infant children.
This matter came on for a final hearing before the Court on
the 20th day of April, 1994. The Petitioner, Helen Barbush, wa.
pre.ent in person and represented by Counsel, William E. Hensley.
The RespondeYlt, Simon William Barbush, J,-., w~s neither p,'esent
in person nor represented by Counsel. The Court, after hearing
testimony of the parties and evidence of the witnesses, makes the
,
following Findings of Facts and Conclusions of Law.
FINDINGS OF FACT
1. Petitioner resides in this state and has been a resident
hereof for 180 days next preceding the filing of this Petition
for Dissolution of Marrlage.
2. Pet it i,:,y,er, Heley, B",'b'.IBh, iB 30 years ,:.f agel she
presently resides at 46 Pine Grove Ap..rtments, Corbin, Kentucky
40701; and she is presently unemployed,
Page I of 5 Pages
~ X~\ (~rr I, f\ "
3. Respondent, Simon William Ba~bush, Jr., i. 43 year. of
age, he p~e.ently ~esides at 307 W. Dauphin Street, Enola,
Penn.ylvania 17025, and he is presently employed at 6t~oehman
Baker, Ha~~isburg, Penn.ylvania.
4. Petitioner and Re.pondent were married on the 11th day
of AuglJst, 1ge7, in Vi~ginia Beech, Vi~ginia, sAid ma,'riage
c:e~tificate being regi.tered in Virginia eeach, Virginia.
5. Pet it ioner and Respondent separated on or abolJt December
15, i992, and have lived .epa~ate and apart since that time.
6. There were two (2) infant chiLd~en born a. a result of
this marriage, namely. Je..ica Marie Barbush, age nine ('3) yea~.,
bh-thdate being July 12, 1ge4, and Simon William aarbush, 111,
age .ill (6) years, birthdate being March e, i'3ee. The inf.:ant
children r~side with the Petitioner.
7. Petitioner states that she i. not now pregnant.
e. There are no marital property nor marital debt. 'or
which the Court i. a.ked to make a distribution, however, there
is a telephone bi 11 in the amolJnt 0' .':;00.(1) which the Respondent
.h,:'uld bil rel>pon.i.,le for.
9. The Petitioner herein ha. not participated in, nor haa
knowledge 0' any other proceeding involving the in'ant children
0' the parties herein pending in this or any other state.
Fyrther, the Petitioner knows of no party to this action who
claims to have custody or visitation rights with re.pect to the
infant children named hereln.
P~ge ~~ of 5 P~ges
10. The Petitioner is the fit and p~oper person to have the
care, custody and control of the infant children, with the
Respondent having reasonable rights of visitation which
visitation shall be supervised by the Petitioner.
In the event
the partie. cannot reach an agreeMent as to the visitation
arrangement, then in that event, the Respondent will be
r.Fponsibln to h~ve the Court M.~. the ~rpropr\~te ch~~~~D.
11. The Re.pondent shall pay the Petitioner the sum of
.173.00 per month as child support for the parties' infant
children.
12. That the marriage between the Petitioner and Respondent
is irretrievaoly broken.
CONLUSIONS OF LAW
,
1. The Court has Jurisdiction of the parties and of the
.ubJect matter of this action.
2. The marriage between the parties should be di.solved for
the reason that such 1. irretrievably broken and Judgment should
be entered accordingly.
3. The Court finds that the best interest of the children
would be served by awarding the custody of the children to the
Petitioner with the Respondent having reasonable rights of
visitation which visitation shall be supervised by the
Petitioner.
In the event the parties cannot reach an agreement
as to the visitation arrangeMent, then in that event, the
Re.pondent will be responsible to have the Court make the
appropriate changes.
P8ge ~ 1:1' 5 r., 'l.
4. The Respondent shall pay to the Pet it ioner the SUM of
.173.00 per month for the support 0' the parties' in'ant
ch 11dre'h
:5. The RRspol"ldel"lt shall pay the phon. bi 11 in the amount 0'
.300.00 to SO'Jthe.'n eell.
G. The decree should contain a wage as.ignment clau.e 'or
~ny .~~ropri.t8 chil~ support arrearage as mandated pursuant to
KR6 403. 2115.
WHEREFORE, IT IS ORDERED, ADJUDGED AND DECREED by the Court
as 'ollows.
1. The marriage previously eKisting betwe.n the Petitioner
and R..pondent be and same i. hereby dis.olved, and each party
is restored to all the rights and privileges of an unmarried
, '
person.
a. The Petitioner is awarded the 'ull care, custody and
control,)' the parties' in'ant children, with the R.spondent
having rea.onable rights 0' visitation which visitation shall b.
supervi.ed by the Petition.r.
In t.he .vent. the parties cannot
reach en agreement .s to the visitation arrangement, then in that
event, the Respondent will be responsible to have the Court make
the appropriate ch.nges.
3. The Re.pondent is to p.y to the Petitioner the sum 0'
$173.':11) pet' moy,th as child sUPPOt't '0., the pat.ties' in'ant
children, this amount is ba.ed on the Commonwealth 0' Kentucky
Worksheet 'or Monthly Child Support Oblig.tion.
4. The Re.pc,y,dent i. tc. pay the ph<:'YI. bi 11 iY. the 'U~<:".lnt 0'
$3(1). .).) to S,)I.,therYI B.ll.
Page 4 of 5 ~lage9
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Simon William Barbush, lr.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
NO. 94-4956 CIVIL 1994
CUSTODY
Helen Barbush,
Defendant
CERTIFICATE OF SERVICE
I, Patrick W, Quinn, Certified Legal Intern, Family Law Clinic, hereby certify that I am
serving a true and correct copy of said Preliminary Objecti.:>ns of Defendant to lurlsdictlon of
Court and, in the Alternative, to Forum on Larence 1, Rosen, Esq" of the Law Offices of
Sanford Krevsky atIlOl North Front Street, Harrisburg, PA 17102, by hand delivery, this 6th
day of September, 1994,
THE FAMILY LAW CLINIC
45 N, Pitt Street
Carlisle, PA 17013
717/240-5204