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Home My WebLink About94-04989 1.1, ;! I , I il " " " 0- CO 0- T " ~ .. ~ ~""J , <""":'" '- " ,', , ' d ; ,''') \,; '.'} ")0; '''-;--- , ,,' ,,' '~ 1-.... ''"1' t-.... ........,-, 10 -", 0- "" V' '-' " JI~_) ......... <....\ t~~.. , ........ \ \ '~r- '~ '..-., "", , ;'~ .J'.... .'< I ~.~~ "1 '-./, -.J " Ii':' , "', '\ ' .~ ..,.- \, ". .-;".,. '. '1 I, ') '. ,.-~" ':- " ..... I/'; ~ \:l ~ 8 -: ... !Xl :s ~ < c(l ~ , ~ fo 5 ~ :< ~ < ~ ... ~ M " ... ~ ~ ~ , \:l i': OJ " c ;< -: It ~ 10: . 0 . .. .... ~ 0 ioI i , -, i' ill " " i:: " 0 " ~ ;.>: ~ ... '. . , SEP ~ 7 19,94/h_ Ii I MICHAEL L. HOLBBRT Ii Pla1ntlff IN THE COURT OF COMMON PI,EAB OF CUMBERLAND COUNTY, PENNBYINANIA CIVIl. ACTION " I,AW NO. 94- CIVIL TERM IN DIVORCE vs. I ROBEMARY Z. HOLBERT Defendant II NOTI~ 91' AVAILABIILITy OP CO!l~.!!.!lI,ING iTO THB WITHIN-NAMBD DBFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed ! in the Court of Common Pleas of Cumberland County. This notice is to advise you that in , accordance ",ith Section 330~(d) of the Divorce Code, you may request that the court , require you and your spouse to attend marriage counseling prior to a divorce being II handed dOlln by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are i: i! advised that this list is kept as a convenience to you and you are not bound to choose :'a counselor from this list. All necessary arrangements and the cost of counseling " : sessions are to be borne by you and your spouse. : I If you desire to pursue counseling, you must make YOllr request for counseling I ",ithin tllenty days of the date on which you receive this notice. Failure to do so ",ill constitute a lIaiver of your right to request counseling. , II , , 2 IIICHABL L. HOLBERT Plaintiff IN THE COURT OF COli liON PLEAS OF CUIIBBRLAND COUNTY, I PENNSYLVANIA VI. , CIVIL ACTION - [,All I ROSIlIlARY Z. HOLBERT Defendant NO. 94- CIVIL TERM IN DIVORCE cotIPLAINT IN DIVORCB !OO!Il! SBCTION 3301(c) Q! 3301(d) Ql THB !!.IVOllCB CODB AND HOW comes the above-named Plaintiff, MICHAEL L. HOLBERT, by his attorneys, Andes, Vaughn & Bangs, and makes the following Complaint in Divorce= 1. The Plaintiff is MICHAEl, L. HOLBERT, an adult individual who currently resides :Iat 1900 Kent Drive, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is ROSEMARY Z. HOLBERT, an adult individual who currently resides at 1900 Kent Drive, Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- " wealth of Pennsylvania for at least six months immediately previous to the filing of ! I this Complaint. I!, 4. The Plaintiff and Defendant were married on January 28, 1989 in Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. :1 1 , I' 1 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the , Plaintiff may have the right to request that the Court requJ.re the parties to partici- 'pate in counseling. J B. The Plaintiff :equests this Court to enter a Decree of Divorce. VHBRBPORB, Plaintiff requests this Court to enter a decree in divorce pursuant to the Divorce Code of Pennsylvania. !;9UtIT I. = ~.mmy , I' 9. Paragl'aphs I through 8 sre Incorporated herein by reference. 10. The Plaintiff and Defendant are the parents of three (3) minor children, I 'Clifford M., DOB 9/23/11; Wesley M., ODD 10/4/83; and corbin, ODD B/28/89. The said minor children reside with Defendant herein. , i, :; 11. Plaintiff seeks visitation with the minor children. i: 12. The children were not born out of wedlock and are presently in the custody of Ii ,! the Defendant. 13. During the past five years, the minor children have resided with the following " 'persons at the following addresses: August 1'/, 1989 to present Plaintiff and Defendant 1900 Kent Dri Vf Camp Hi 11, PA 14. The mother of the child is the Defendant who resides at the address set out above. She is married to the Plaintiff. l!l. The father of the children is the Plaintiff who resides at the address set out above. He is married to the Defendant. 16. The Defendant is the natural mother of the children. Defendant currently resides with the following person: the minor children. 17. The Piaintiff is the natural father of the children. Plaintiff currently , resides with the following persons: himself. 18. The Plaintiff has not participated as a party or in any other way in any litigation con~erning the custody 01 the children in this or any other court. 4 " r -:7" l'''' :' ; fl'l ",., l,') ,.'/ ,-- , , (.-.- , <I: \:l ~ ~ t .-. c to " ~ ~ ~ :i < JJ ~ ~ ~ 5 ~ ,< :I. < :j II: 'Ii I'! ~ >- I:J ~ ~ 0 'Ii >J ~ ~ i': < ~ II: d ~ ;,. 0 ~ Q; Q; 'Ii ~ ? iJ il.I ~ ,- >- >l d 0 ~ " ~ ~ " ~ - ~, .: . .. I IN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I INO. 4989 - CIVIL - 1994 t I ICIVIL ACTION - CUSTODY MICHABL L. HOLBERT, Plaintiff v ROSEMARY Z. HOLBERT, Defendant fJI'C r' :. , I) 1QgJ~,/~ t4 COURT ORDER AND NOW, this.:) k' day of ~uv. , 1994, the Conoiliator being advised that the parties have reaohed an agreement, the Conoiliator relinquishes jurisdiotion. " re UfC ,I ~J (1) 1'1/ '9~ " I , 'I" L " " OEC\'\' Illl~ :\\llg~ I II ~ I,. J:! [,01. " \1.\ ,I , , .II I, , , ' I i II 'I HICHAl-:L L. HOLBERT, ) IN THB COURT OF COMHON Plaintiff ) PLEAS Of' CUHBBRI,AND ) COUNTY, PENNSYLVANIA I VII. ) II ) CIVIL ACTION - LAW ) :ROSEMARY Z. HOLBERT ) NO. 94-4989 CIVIL TERM Defendant ) STIPULATION AND NOW. comes the Plaintiff. Michael L. Holbert and the Defendant, Rosemary Z. I ! Holbert, and enter Into the followinq 6tipulation reqardinq the custody of their minor children, Clitford M. (008 9n3/'1'I); We6ley M. (DOB 10/4/83; and Corbin (DOB 8/28/89), '! and a6k the stipUlation be made an Order of Court. The stipulation is as follow6: 1. The parties will share legal custody of the childr~n. 2. Mother will have primary physical custody of the children sUbject to periods !iof partial custody and visitation with the Father as follows: A. Every other weekend from Friday to Sunday at times agreed upon by the parties. B. One week in the summer. Father to provide Mother with thirty (30) days notice of the week chosen. C. Accesll to the children over the major holidays, incIudinq Easter, Memorial Day, Fourth of July, Labor Day, Thanksgiving and Christmas, at times to be agreed upon by the parties. D. Such ot)1er times as may be f~~-(~~~\{~ ~~_____ Michael L. Bangs 4 Attorney for PlaintYff agreed upon. ~~ ~' ( .- -- (".....Y ( -. ..,~~>... MI HA I, L. HOLBERT J ~~~BSqUire ~y for Defendant , " ) ,// '/~' " ROS!MA)lY Z.1I0LBERT--