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Home My WebLink About94-05476 ~ ~ c o ./) (I~:\ '.' -7 If) IV C o /) ~ ,J ~ f:'.. ~ to " I ~ " \'; :.:. .;+:.:+;. -:+:. .;+;. .;.: .;+:. ~.;. .:+:. .;+: -:.:. :.:. .:+;. :.;- :.: .:+;, -:.;,:.:. :+: <+: +,_ :+:. -:.:, -:+; ;+:. -:.;. .:+;. .:+;. <+:. ';4 ~ ~ ~ ~ ~ :~: ,~ :~: :.. IN THE COURT OF COMMON PLEAS .. ;',' OF CUMBERLAND COUf\ITY ) . i~ I \~ \." I~ I':' ~~ I~ i,:, :'~ i. !'+ }'." i~ ~~ I, (~: I~ I':' i~ ; , ;~ I.. !~ 1". ~ ~i ~~' :~~,~~~' t, 1_ "';L:'~~~'. ' \. .",,"~~Jf' PENNA. :~ I STATE OF ~. ~ ~ ~ ~ DEBRA L. JONES, Plaintiff i\: ( ), 94-5476 II) ~ \. I' j'~ II; ~ scorr D. JONES, ~ ~ Defendant ~ . ) ~ DECREE IN DIVORCE ~; , ~ "1 ~~ AND NOW.~.",,,~ .1. ..,. ,." 19 Cf$'.., it is Ordp.rlHi I1nn dp.uHfln thot, Delq t.a.. ./..., 'J c>>oe.s.".. "..... ..,'. plt:1intiff. ann ,Sc.,o-tr J>.lo"~~.... ,...., dp.lfmdl']nt, ore divorcf!c! from thp. honns of matrimony, i~ ~l ~I ~I ':'\ ~l' ~ ':'1 '.1 , ~I ':'\ .) '.'1 ~ ~ , ~ ~ '~ , I,'. ,~ ~ i,', ;:!,. Thp. collrt wtains illrisdiction of the foll()win~ r.Ioims which hnvp. hep.n roisf!n of rp.cord in this oct ion for which a final ordfH has not yet hp.en p.ntp.rfld; ~ ~ None ~ ~ ~ ~ it, ~ .: '.: ~ :..~ :~> .:.:- .-+; :..: 1': ..' '.; ~ Itv Till'. liLt. oLr., , ^"",,, J)6""",<,' 0'Uf., IJM!t,J' iJ,'/' 1>I;"(."'l r. :-.;t.( ~...l.dl.-t1-.r 'l I / PI'IIIIII1I1OI.II \ ~ :~ ~ .~ ~~ , ~: f, " ..:-:- ':..~, <.:. .;.:. .:.:. .': :~ '.~ <.:- :+: :.:- :.:- '-+:' .;.:- .:., -:+:. -:.:-:+:- :.:- :.;. :.:-.: (.,.) .%5 ad Lo/! /lfIlJl/to rd4- ~0 fp.,} .'/5" 1Mue 1,,dJlt/ It, iii~ fbJh i! DEBRA L. JONES, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Planitiff v. NO. 94-5476 Civil Term SCOTT D. JONES, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(C) of the Divorce Code. 2. Date and manner of service of the complaint upon the defendant: service on the defendant made via certified mail on October 7, 1994 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff, May 23, 1995; by defendant, May 1, 1995. 4. Related claims pending: None. 219 East street Mechanicsburg, PA 17055 (717) 795-9277 date: May 23, 1995 c.... rTl ~= c... .' .1 "-l ; J ".:t I .I Ii l' ; !. .. DEBRA L. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. }'-/. "1/ 'l(~ (~l.(.rt-/ 0{__,_ SCOTT D. JONES, Defendant IN DIVORCE NOTICE TO DEPEND AND CLAIK RIGHTS 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 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, including custody or visitation of your children. 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 Cumberland county Courthouse in carlisle, Pennsylvania (telephone number (717) 697-0371 or (717) 240-6100] . 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 OllCE. 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 4th Floor, Cumberland county Courthouse Carlisle, Pennsylvania 17913 Telephone: (717) 697-0371 or (717) 240-6100 DEBRA L. JONES, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. SCOTT D. JONES, Defendant IN DIVORCE COUNT I COMPLAINT IN DIVORCE 1. Plaintiff is DEBRA L. JONES, who currently resides at 90 Rolo court, Mechanicsburg, Cumberland County, Pennsylvania since 1977. 2. Defendant is SCOTT D. JONES, who currently resides at 16 Spring Lane Road, Dillisburg, York County Pennsylvania, since June, 1993. 3. Neither Plaintiff nor Defendant are minors or incompetent. 4. plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on the September 8, 1979, in Mount Holly Springs, Pennsylvania. 6. There are no pending or prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that , i this Honorable Court require the parties to participate in counseling. 8. Plaintiff avers as the grounds upon which this action is based are as follows: (a) Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and her life burdensome; (b) Defendant has committed willful and malicious desertion, and absence from the habitation of the Plaintiff, the injured and innocent spouse, without a reasonable cause, for a period in excess of one year, and (c) the marriage between the parties is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce. COUNT II REQUEST THAT COURT EQUITABLY DIVIDE MARITAL PROPERY UNDER SECTION 3502 OF THE DIVORCE CODE The foregoing averments contained in paragraphs 1 through 8 are incorporated herein. 9. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. They have been unable to reach an agreement as to the distribution of such property. WHEREFORE, Plaintiff requests this Honorable Court to determine and equitably divide the marital property under the provisions of Section 3502 of the Divorce Code. COUNT III CLAIM FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE & CLAIM FOR ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE The foregoing averments contained in paragraphs 1 through 9 are incorporated herein. 10. Plaintiff does not have sufficient fund to support herself or pay counsel fees and expenses incident to her divorce action and her complaint for custody of her two minor children, said complaint being filed simultaneous with this complaint. 11. Plaintiff is employed as a pharmacy billing clerk and secretary at Health South Rehabilitation Center, Mechanics- burg, Pennsylvania, and earns approximately $205.00 per week. Defendant is employed by Cresline Plastic Pipe, in Mechanicsburg, Pennsylvania; Plaintiff believes and therefore avers that Defendant earns approximately $400.00 per week. WHEREFORE, Plaintiff requests this Honorable Court to award just and reasonable alimony, alimony pendente lite, counsel fees and expenses incident to this action.~ ------- '. ..---' . /" / . - .------ ~ //y ._-~// ;/;.. /1", /"j , {.."c'''C,.. ". _' Thomas M. Kutz, Attorney for Plainfiff 1.0. No 3SSS7 J 219 East Main Street Mechanicsburg, PA 17055 date: ':/;.!~/~)<;/ '/ / " ) 4 I ,~. ,1 j \~ J , . 't (,:\.:: .~1 >< ''I t" tl ., <> " .) " ^ " '0 " t: .. , " '-, .... ~ ... ... <> ~ .. " .... ... \ \r f " ~ ". c.>.. ~) '", fV\ '~ ~ , .,. .J " . .1 ~ J ~Ij ... r i \> . ,,') " ~ 1'1 .... "'l "" l'\) . l1" ...., to, ~ ....,,.) .--~-' en : I"~ .J r;. ,,, L'.... ;) " . -' .... DEBRA L. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 94-5476 SCOTT D. JONES, Defendant IN DIVORCE CERTIrICATE or SERVICE I, Thomas M. Kutz, Esquire, do hereby certify that I served a true and correct copy of the Complaint in Divorce for the above captioned matter on the Defendant, SCOTT D. JONES, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested and postage prepaid. The return receipt for said certified mailing bearing the Defendant's signature and postmarked October 1, 1994, is attached. _.-------::-. c ./. ,.",'./" /,' , / '/ --? /' J :,/" ,./___: ' ,'. ,.#"/....-:::.,..... I~.... ",\ Thomas M. Kutz, Esquire Attorney for Defe~ant 219 EaSt H6in Street Mechanicsburg, PA 17055 / Attorney I.D. NO. 38887 date: r.'("r~ /11;/ . ,. , Jones v. Jones Cumbo Co. No. 94-5416 certificats of Service Page 2 ,.. . t . eom,a.tI i.... l' Ind/or 2 for NdhionII ..meet. 1~~_3._"..' . Print your Nmt end Idd,... on the ,.11.'" of tNt form to thlt w. eM Mut.-1 "" cltd to you. ! . AnKh \hi. form 10 ,.... rront 01 the mli6p6K., or on the bKll If aptcI . dota nol petmlt. J . '11m "".turn Receipt R~'I~" on I'ht m~. below the tttidt' numbltr . The Return Rte*pt wlU.now to whom the ~ w.. eMtiy.rtd and IN dati & d.Ilv.,td. 1 3. Antele Add'.lIed to: t ft .;./ r> lill~" ~r'(:;i7 /) ;;r;..v~- 5 I ,110 wish to recllvl the following ."vle.. (for In Ixtr. feel: 1. 0 Add"...... Add.... 2. ~R..trlct.d Delivery Consult Oltmaater for f... 4., A;t'Jfge,& ~ 1'/:< Y 4b. S.,...icI Type o Registered E1 Cenilled o Exprll8 Mail i l- I i ! ! 8. Addfl...... Addre.. IOnly if requllh,d 11. and fe. I' paid I ~ I w tr: Cl ~ (/;<'AIVT,v'1'( /~. I I'd /7C;.7 o Inlured o coo o Return Receipt for M ,chandl.. 7. Date of Delivery D ,/ '/1 r,l1, (..lOX /. PS Form .l!I .O.c.mber 1991 .U,..""""..........71. DOMESTIC RETURN RECEIPT I DEBRA L. JONES, I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA planititt v. NO. 94-5476 Civil Term SCOTT D. JONES, Detendant IN DIVORCE urIDAVIT or CON8I11T 1. A complaint in divorce under section 3301(c) ot the Divorce Code was tiled on September 26, 1994. 2. The marriage of the plaintiff and detendant is irretreivably broken and ninety (90) days have elapsed from the date ot tiling the Complaint. 3. I consent to the entry of a tinal decree ot divorce. I verify that the statements made in this affidavit are true and correct. I understand that talse statements herein are made subject to the penalties ot 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. ;( ~ l I I ; 1 j j 'J 4. I understand that I may lose rights concerning alimony, division ot property, lawyers's fees or expenses if I do not claim them before a divorce is granted. i 'I '", " Date I 5'<~ 3.(('5" DEBRA "tt. ~~~'a, ':-:::-)) .(\'n-J Plaintift " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBRA L. JONES, plaintiff, CIVIL DIVISION LAW v. NO. 94-5476 Civil Term SCOTT D. JONES, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 26, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 16 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: S-)- 9 S- ~ ec-t;f "t O~ Scott D. ()f6nes DEBRA L. JONES, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. -- NO. '/'/. ~/ I ~lf# ('(1..1 I,~..~ SCOTT D. JONES, Defendant IN DIVORCE ORDER or COURT AND NOW, this -;')~ 1.\ day of ';v/ ,(,",}>t/ , 1994, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before (~, , '" ," \ ( I!" I 'I , the conci liator, at ~,,),) 1\\ /;)1..,1 '~","i'l(" on the .~ \" day of II. ,... _, 1994, at '.Lt.!...m., 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 shall (may) also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, , ;' . I I I.- ---..'--/L 'J~i0- custody Conc 1 By: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 TELEPHONE: (717) 240-6200 ';[1' ,I) ~ lJ. I f9~ " ,T ,1 DEBRA L. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUM~ERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. r/,/ - ,', /'- (.'l";; -- J.'.." " SCOTT D. JONES, Defendant IN DIVORCE COMPLAINT FOR CUSTODY 1. Plaintiff is DEBRA L. JONES, who currently Rolo Court, Mechanicsburg, Cumberland County, resides at 90 Pennsylvania. 2. Defendant is SCOTT D. JONES, who currently resides at 16 spring Lane Road, Dillisburg, York County Pennsylvania, since June, 1993. 3. Plaintiff seeks custody of the following children: MICHELLE L. JONES 90 Rolo Court Mechanicsburg, Pennsylvania date of birth: December 20, 1983 DOUGLAS A. JONES 90 Rolo Court Mecnanicsburg, Pennsylvania date of birth: February 26, 1987 The children were not born out of wedlock. The children are presently in the custody of the Plaintiff, currently residing at 90 Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania. From their births to present the children have resided with following persons and at the following address: , . (1) trom birth to June, 1993, at 90 Rolo court, Hechanicsburg, pennsylvania with both plaintiff and Defendant. (2) from June, 1993, to present, at 90 Rolo Court, Hechanicsburg, pennsylvania with Plaintiff. The mother of the children is the Plaintiff, DEBRA L. JONES. She is presently married to Defendant. The father of the children is the Defendant, SCOTT D. JONES. He is presently married to Plaintiff. 4. The relationship of Plaintiff to the children is that of biological mother. The Plaintiff currently resides with her children in Mechanicsburg, Pennsylvania. 5. The relationship of Defendant to the children is that of biological father. The Defendant currently resides with his parents in Dillsburg, Pennsylvania. 6. Plaintiff has not participated as a party or witness, or in anoth~r capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. plaintiff does not know of a person not a party to the proceedings who has 9hysical custody of the children or claims to have custody or visitation rights with respect to the children. 7. children will The best interest and permanent welfare of the be served by granting the relief requested because: . . a. the Plaintiff has served as primary care giver of the children since their births; and b. the Plaintiff has filed, simultaneous with this complaint, a complaint for divorce insofar as Defendant has absented himself from the marital home for a period in excess of one year. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WEREFORE, Plaintiff requests the Court to grant both physical and legal custody of her minor children to her. .0" ...--..--"'} /' -_.,.-- " .- --------# ///-;.-/ ///'u/4." /!... ...-~" Thomas M. Kutz, E quire Attorney for Plan tiff Supreme Court lID. No. 38887 '-'-- 219 East Main Street Mechanicsburg, PA 17055 Telephone: (717)795-9277 da te : ~ (;;>r. X 6- /'/9 r.; ,; / .. . VBRI'ICATIOH I verify that the statements made in the attached Pleading are true and correct. I understand that false statement~ made herein are oubject to the penalties of 18 Pa.Cons.stat. sec. 4904 relating to unsworn falsification to authorities. ~ Debra I , L. Jones l' .- n . J -i ~ ;."'t- ...) () J"o. , ~ "- l. · ~J J , "" " i I ~ : '..; .;' "':Or' ~n ~' tJ-- r:... ~ >l -,~ ... , ,';-; , !\ If .- DEBRA L. JONES, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 94-5476 civil Term SCOTT D. JONES Defendant IN DIVORCE CIRTIrICATB or SIRVICI I, Thomas M. Kutz, Esquire, do hereby certify that I served a true and correct copy of the complaint for custody and Order of Court setting a concilation conference for the above captioned matter on the Defendant, SCOTT D. JONES, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested and postage prepaid. The return receipt bearing the Defendant's signature and showing a delivery date of October 7, 1994, is attached. n__~ /:.:;- .l:;'l: {/ / //,// '. ,/ /~:;: I.'.t t".. .'.t..." ~ , ( ,. ) Thomas M. Kutz, Esquire Attorney (or Def~n4ant 219 East Main Stpeet Mecnahl~~bu~g, FA 17055 Attorney 1.0. NO. 38887 date: /0//(/7/ / / . . ,. . . Jon.. v. Jon.. Cumbo Co. No. 94-5476 Certificate of Service Page 2 1- Complete ttemI 1 Iftd/Of J lot IddhlonaI ..fVka.. . Comple~ ft."" 3. Iftd oW . b. ... . Print _ '- ond _n. on .... ,...... .. ,N. fonn .. ."". "0 .on J' ' Ntum thlI ~ 10 you. . Anach INt form to the front of the ~.. Of on the beck Ir '~C41 ~~~. I J . W,*""ttum"~tR~It.d"onthl~belo.lM.udlnumber 2. . TN fln.rn Receipt *,1 tho"" to whom the artlc" \Ir" dd....red end thtllltll 8 \MW.,erM. Con.ult oltm.al., for 'Ie. J 3, Articlo Add..uod '0: 40, Articlo 2t; 3'7<<07$'3/ 1 ~ ~c:;# 0K'-S 4b, Sorvlco Typo i II (~. / 0 Rogi..o..d 0 In.urod PC!. ~""x' 2// ~Cortiflod 0 coo /? 0 bpI'" Mail 0 A.lurn Re~.lpt 'or ~....cu<.-//.' C'O......, h 1/0.21 7, Do.. of DOIiVio y ;orchond,.e ! /o_'7t!7 I 8. Addr.......' Add,es. IOnly if requllted t and ,.. II paidl ~ I 1110 with to receive the following lervlce. l'or an .xtr. 'HI: 1. o Add"...... Add"D Ii:1'R.'trlcted O.lIvery ~~~' 8. Sign.tur. (A PS Form .II . December 1991 ......ClI'a._114 DOMESTIC RETURN RECEIPT , DEBRA L. JONES, Plaintiff IN THZ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSVLVANIA CIVIL ACTION - LAW v. NO. 94-5476 civil Term SCOTT D. JONES, Defendant IN DIVORCE CUSTODY ORDER AND NOW, this '.:,J day of _Iv , .. l"i , 1994, upon consideration of Stipulation of the parties concerning custody of their minor children, the following Custody Order is entered: 1. The Mother shall have primary physical custody of their minor children, Michelle L. Jones and Douglas A. Jones. 2. The Father shall have visitation and/or partial physical custody rights to the children as follows: a. on alternating weekends beginning with the weekend of November 11th through November 13th, 1994, b. the times for the Father's visitation weekends will alternate as follows: (1) for one weekend the visit shall run from 5:00 p.m. on Friday to 4:00 p.m. Sunday; (2) for the next weekend the visit shall run from 10:00 a.m. on Saturday to 5:00 p.m. on Sunday. 3. The Mother and Father shall share legal custody of their children. Insofar as the Mother has been and will continue " I' I! . 11 ,. ~ ~ ! I j . , 1. The Mother shall have primary physical custody of both children. 2. The Father shall have visitation and/or partial physical custody rights to the children as follows: a. on alternating weekends beginning with the weekend of November 11th through November 13th, 1994, b. the times for the Father's visitation weekends will alternate as follows: (1) for one weekend the visit shall run from 5:00 p.m. on Friday to 4:00 p.m. Sunday; (2) for the next weekend the visit shall. run from 10:00 a.m. on Saturday to 5:00 p.m. on Sunday. 3. The Mother and Father shall share legal custody of their children. Insofar as the Mother has been and will continue to be the primary care provider for both children, the Father agrees to defer to the Mother's jUdgment regarding the health needs, education and religious training of the children. The Mother in turn agrees that she will at all times advise the Father of the previously stated ne~ds and tr~ining of their children. 4. The Mother and Father further agree that each will notify the other of all medical care either child receives while in that parent's custody. Each parent will notify the other immediately of medical emergencies which may arise while the children are in that parent's care. . 4 ~ r 5. The Mother and Father, by mutual agreement, may vary trom this schedule at any time but the Order shall remain in ettect until either parent petitions to have it modified or changed. IN WITNESS THEREOF, the parties execute this agreement and request that a Custody Order be entered to reflect its terms. 2CA-tJ, ~9~~ tA~ Scott D. one~ efendant ,/ , ( '\ .J ff (" Jones .,. '/ , /. /~. ./-.... . ,,::-,,,_~, ~ / t' " Thomas M. Kutz, Es~~ire I / " ' 1(' steph~h \ ~. ' ~~rtko :: r E~~ut~ I 101 Office Center, suite A 101 South U.S. Route 15 Dillsburg, PA 17019 (717) 432-9706 , ,-- Frankebe~jptace 219 East Main Street Mechanicsburg, PA 17055 (717) 795-9277 u ~ NOV 2 ~ 1QQA 'J. ....... ".., ~. ~J . PIlIIIIIII"'tl'''ltt LA WRt:I'Kt: E. Wt:I.Kt:R CUMIII.N1ANIJ ClIIJNn CAMlISl... I'A I7Ull .......-. "". )z.A\ L/ 11111 ,f'- ROO! ]to "11" 1701'h... ro .....0 " 'EIa....\._(, ~.~>l' ""-'rO --L "fJ'''t. Scott D. Jones 16 Spring Lane Di11sburg. Pa. ^ .' t , '. i I J ~ .- , , v. IN 'rHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. I, '/. 'j 1"/1, (.( ,', ( ~T~ '-, DEBRA L. JONES, Plaintiff SCOTT D. JONF.S, Defendant IN DIVORCE ORDER OJ' COURT AnD NOW, this .V.I";)' day of S;..) 1$', I ,lie I:> , 1~94, f upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before SJ;ln." , t l L I),'ct.'" f;...... , the conciliator, at .b, Ill. 1.)11. c..':j 1.,,,.;.,,./ J , on the 'pi), day of Ah'J ,,,1-.< /" , 1994, at-'i-p...m., 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 shall (may) also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: /y \~. ." ,u,I;~air 6.. .../.' '}' [.uv C stody Concili r U . 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. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4TH FLOOR CARLISLE, PA 17013 TELEPHONE: (717) 240-6200 . DEBRA L. JONES, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. SCOTT D. JONES, Defendant IN DIVORCE COMPLAINT FOR CUSTODY 1. plaintiff is DEBRA L. JONES, who currently Rolo court, Mechanicsburg, Cumberland county, resides at 90 Pennsylvania. 2. Defendant is SCOTT D. JONES, who currently resides at 16 Spring Lane Road, Dillisburg, York county Pennsylvania, since June, 1993. 3. Plaintiff seeks custody of the following children: MICHELLE L. JONES 90 Rolo Court Mechanicsburg, Pennsylvania date of birth: December 20, 1983 DOUGLAS A. JONES 90 Rolo Court Mechanicsburg, Pennsylvania date of birth: February 26, 1987 The children were not born out of wedlock. The children are presently in the custody of the Plaintiff, currently residing at 90 Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania. From their births to present the children have resided with following persons and at the following address: V!RJ'ICATION I verify that the statements made in the attached Pleading are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.Cons.stat. sec. 4904 relating to unsworn falsification to authorities. \ c\ Debra . .-. 1- .. L. Jones I _" ~