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Home My WebLink About95-01135 tt...7.i'~:'",' . ~~t.~,"'J:-,; . :~(~x'\L. . \"., 3ii fft'~~.~ ~'\:;' ;;,. ci> ' H~)~, ~fi."v/:" ~~;~ '" z" !J;i> ~t;;~,(~: , i~if))";~:';: ,-, , '.. ~*~~, .,-,! :f;'JI:'~~"f '-' :. " , '" -~(~i ~ ",- ~ -:,.. i '~,}f.c ~~,:,':~" ~. \{ , ',"-,'. l '~{;";/~""'..>, .;- ,-'" .' z: ,\>~~l. \-: ':r; :!'_~_/>: ;~~?~~,: .: '~'~... I. ...J'.' ~-;1 :". ''- _.' :"'-'; '" ii', , ~-~\ - ~~', .,,:.:- t~t; 'f>\- , . ",' ;.- '.' <}"'?':,~,~i,.. ", Of " . \' .. '-,,,' ! I il q \i : TliOMAS q " !> ': I I' ,I A. STEINOUR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-1135 CIVIL TERM I , v. Ii I cYNTHIA I :1 J. STEINOUR, Defendant IN DIVORCE Ii 'I I, 'I II 'I " ORDER OF COURT : ~ II I :0,6. AND NOW, this~ i I, i: i .the Plaintiff and Defendant regarding custody and child support i 1 dated June B, 1995 is hereby adopted as an ORDER OF COURT. 1995, the stipulation of !. ii I, I. , J. , 1 '1 , II II " ;) i, il ,~, L_ C :z; r--> = ,: '. L ,:.'.: w ','- N "\":: .s;.: .-" --0 :x: , :" I I: - , -'I;;. ....-: u:> C..T1 'I \1 I. '[THOMAS A. STEINOUR, : i Plaintiff ! IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95-1135 CIVIL TERM v. i: CYNTHIA J. STEINOUR, Defendant .' IN DIVORCE " i: :1 , :i " CUSTODY and CHILD SUPPORT STIPULATION THIS STIPULATION is made this 6th day of June, 1995, by and . 'between Cynthia J. Steinour, of 60 Hanna Road, Newburg, Cumberland , I: :County, Pennsylvania, (hereinafter referred to as "Mother") and '!Thomas A. Steinour, of 60 Hanna Road, Newburg, Cumberland County, I Pennsylvania, (hereinafter referred to as "Father"). WITNESSETH WHEREAS, Mother and Father are the natural parents of the following minor children: Michael Reed Steinour born May 10, 1960; Megan Lee Steinour born May 19, 1962; Katharine Jane Steinour born April 6, 1966; and Robert Benjamin Steinour born September 16, 1992; WHEREAS, in light of their imminent divorce and separation, i[Mother and Father desire to amicably resolve and setting forth a court order their agreements relative to the custody and child support related to these minor children; NOW THEREFORE, the parties, in an effort to amicably resolve these issues and intending to be legally bound, do agree as . follows: 1. Father and Mother shall have shared legal custody of the ; Ii , : parties' minor children. Major decisions affecting the best , I ! interests of the said minor children, including but not necessarily Llimited to, medical, religious, and educational decisions, shall be ;! ;: ! made jointly by the parties. i 2. Primary physical custody of the children Megan Lee, iKatherine Jane, and Robert Benjamin shall be with her Mother. Ilprimary physical custody of the child Michael Reed shall be with 'ihis Father. " , , Ii i I 3. Each party shall have rights of temporary custody of the ii i'child or children not in his or her primary custody as the parties ! : can agree. It is intended that all children shall be united I , : together for custody with each parent at least for a full weekend I; " Ileach month and at such other times as the parties can arrange II ;1 iigiving consideration to Father's work schedule. ,I ., !i " " 1j 'I 4. Each party shall have at least two (2) weeks per summer of I, " !l !fUll physical custody of all four children. Each party shall give ,i the other at least twenty (20) days notice of their choice of , ': weeks. Said weeks may be consecutive. " 5. The parties shall alternate custody of the children on the holidays of New Year's Day, Memorial Day, Fourth of July, Labor Day, and Thanksgiving Day. Father shall have Fourth of July to commence the rotation in 1995. ALL children shall be with Mother 3 ;j I. I it , " " ~ i Ii ,i :;on Mother's Day and with Father on Father's Day. The parties shall ., "share the children's birthdays as they can arrange. If his work 'schedule prohibits the Father from sharing birthdays of the :1 : 'children, Father shall be enti t:led to an addi tional custody day at 'ia time convenient to him. All children shall be with Mother on "Mother's birthday and with Father on Father's birthday as they can :! : ',arrange. Holidays and special visitation will take precedence over : iregularly scheduled periods of monthly visitation. :1 'I 6. Christmas shall be shared between the parties and divided :i .,so that the holiday is divided into two segments. Mother shall ii I,have custody of all four children from Christmas Eve at 9 a.m. I' i:through Christmas Day at noon. Father shall have custody of all !! :t :Ichildren from noon on Christmas Day through December 26 at 6 p.m. )! , .i 7. Each parent shall have reasonable phone calling ,Iprivileges with the child when in the custody of the other parent. l; B. The parties further agree that Father shall pay to Mother iFIVE HUNDRED AND XX/l00 ($500.00) DOLLARS per month per child in ;:child support. Commencing on July 15, 1995, Father shall pay to ,Mother the sum of ONE THOUSAND FIVE HUNDRED AND XX/l00 ($1,500) DOLLARS per month as child support for the children, Megan, .Katharine and Robert, who are in Mother's custOdy at present. Said "sum was arrived at by negotiations of the parties and reflect the fact that Father has primary xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 4 __' "_0 T l . ...~.-..o__..~,.. o ,. + 0 ,"". 'I' .+ - . .,,- +. _ il'\...t: I . -- -' -"'" '0 J .. , . . '. , Ii I, iphysical custody of the parties' son, Michael. Matters of health I 'insurance coverage, non-covered medical expenses, and child care i f lexpenses shall be paid in accordance wi th paragraph 6.3 of the " i iiparties' separation and property settlement agreement executed !l ! IsimUl taneousl y herewi th. , (, :! II 9. The parties are in agreement that this stipulation shall Ii iibe entered as a Court Order. The Order shall be filed in the Court iof Common pleas of Cumberland County, Pennsylvania. , " I 'I :\ ii IN WITNESS hereof, the parties have set their hands and seals " " lion the date first written above. Netenal Seal Robin J, Goshorn, Notary Public Carlisle Bora, Cumberland County My Cemmlsslon E'plres April 17, 1999 Sworn 0 an su sc befor;;:e this I'ltA day of , ~ , 1995 .~~~ dN-L~-- N TARY P IC I jFATHER: I , fA Gj- ' Pt. 1)Uv~ q il . : MOTHER: i! I I 1 , I , i I ! ~ ; 5 thi.,1;)j~.1l t\.llbWl f..tln'rj;.r ~'\i"~I'-I:' t*1t",.,. PI~lC Nt....,. O,ln;_ "'.1' ~l t}'lf, (;II":r.',..;~nr1' /11.nrv M~ (""r.\f(1l1';.;<.."1iI:.[,,I; .:0,1' "JU _.~._- -....-; .......:-,---TI'-~I ~ Mt'l)'t.;1 ~;'."'Il,I':.-.1r~, ,..;. f),. j'." \ II ". l.l. " Lr>> en ;-'. Ii .,~ 7- J,. ::J'" ~ \.o..i.,,-: '';';0--'. .,' en ::. :-i '-! "; :1!" -;:~ ~'_. ~~ ;._! .r;Jl ..1 _ , c., oJ, ~.; , IIJ~' t- . '/~.l:~J r-..a 1'".;; :5r.: 4 . '" - => -, -, , .' .. '. L, . . u-~ -;:-1 cI -. ..) ~ ~ ~ ~ ~'*' .~ ~~ \:) ~ ~ " ~ '1 J Pi'; Cl - d Z l3 <l: r- > - J ~ .J Z :l t; ~ Ul .. ;J etd~~ ;;: .J .. Z .. 0.. "z o ::E Q W " :l i< Do ::l Ul ID ci c( ~ z Q: " :s <l: a: m W. 0:: m <l: ~ m G ~ z " . . . . fIII'P . . . ,,:+:.".:+:...:.:- .:.:..:.:._ .:.:. .:.-:..:+:. ".:.:. .:.:.' .:.:. -.:.:. .;.:. .:.:. .:.:. .:+:. .:.:. .:.:. .:.:. .:.:..:-:~.:.:.::.:.:.::.:.:...:.:.:.;,.:.:.: .:.:..:.:.::.:.>::.:.x~-;.. ,', --......- .... . t- M ;.~ r': :f. ~ ~, ~ ~ IN THE COURT OF COMMON PLEAS ~ ~ ~ ~' y t' " ~ OF CUMBERLAND COUNTY ~ ~ ~ ~', '.~ ~ ~.' ~ STATE OF ~~ ry \ I, t ....." ~. "":""~~.J',.~r .;, ~ ~ ~.' ~.; ~ ~ ',' !t! "~ PENNA. ~ .. .. ,'~ ~ .'. ~ w. ~.~ ~ .' " ....."., .......... il 'lllOMAS A. STEINOUR ........... .... ...J ......... n'n ...... Plaintiff.n N (), nn9.5.::.1.P:?nn n'~!.Y,P~.. 19 95 ,.; ~ ~ :'~ .'. ~ ~ ~. ~ ',' !~ ~ ~.' i:i ~ ~ ',' ..................., ,; VCI':itl:; '! ~ .. ~.; ~ ~.; ~ ,'i ,'. ~ w ~.' ~'t ~ ~.; ~ M ,'. i; ~ ~'. 1..' ~ ,', ~ r-~ .;, ~ ! ~ W ~.~ ~ ~ ~.' ~ fo: l,. t' CYNIlIIA J. STEINOUR ........... ......... .... . I. . Defendant ;! DECREE IN DIVORCE~ AND NOW, .. )l\!,y, ,......(.~....,..,.., 19.. 95... it ;~s~PA ~ Is ordered and '.; !!! t'} ~ :.~ ~.; ~ " w ~:: !II. ~.~ ~ ',' decreed that ",lhPfllllll, A., S.tl'!.inpur, , , , , , , ,',' , " , . , , , , " , , , " '. plaintiff, and ", , , , ,~y'I)~~~!!, ~ ~ ,~~~~l)C?l!~ , . , , , , , , . , , , , . , , , , . , , ' , , , , , , , , " defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered: ~ ~.' ~ ',' .'. ~ ~ ',' None .......... ...... ........ I" ,t. to... ,t. .... ...... ,., ......... '.' ......... ", ~ . II ..... " .... ...,.. t. ...... .,.. " ........ to It .......... ,0, w ',' ~ :' M I ~ ~ v p ^ . ~ i 4.~~;':/ r~I:"{tl7 J. I: ~ 1;/ ~{;.~onolnrY !;. ~ ~ ~ ,~~:;.;~.>>; ~ ..:...:+!.~~.;;-.i:: ::.:. '.i.:: .::.:. . .:.; - ::.:. ~ .:+:. .:+:. .:.:. .:.:. .:+:. .:+:. ',:+:. .:+:. .:.:. .:.,:. .:+:. .:+:. .:+:. .:+:. .:+:. .:~:~. ~ ',' 7./) ~5 6v-l I~ ~/~$ ~ g. ~ . 7. 1/ ,fr '71K~ /J1ad1~ ,(J. ~ -~~ ,\ ,1 llIcr-IAS A. STEINOUR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 95-1135 CIVIL 1L'RM vs. CYN1lIIA J. STEINOUR, Defendant PRAECIPB To the Prothonotary: Transmit the record, together with the following : IN DIVORCE TO TRANSMIT RECORD information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under (Strike out Section 3301 (c) xilil~~II~xfxKk of the Divorce Code. inapplicable section.) 2. Date and manner of service of the complaint: by certified mail, restricted delivery on ~~rch 17, 1995 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by section 3301(c) of the Divorce Code: by the plaintiff: Julv 3, 1995 June 23, 1995 ; by Defendant (b) (1) Date of execution of the plaintiff's affidavit required by section 3301(d) of the Divorce Code: N/A (2) Date of service of the Plaintiff's affidavit upon the Defendant: N/A 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d) (l) () of the Divorce Code. N/A Bradley L. Griffie, (Plaintiff) (~~~~) , .' "'~"'''''.'''''-~,.'' ! ......... .-','~;j".t ~~ , ,. I ' . , . . Ln en ~ ,. .t::- "I : "1' ,41 (.1 .~ ~.;' _.~ =c: ,,- .... .... N '-0 " ,. "".1 , J. -' ~ ....' " :.1'- v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95- 1135 CIVIL TERM IN DIVORCE THOMAS A. STEINOUR, Plaintiff CYNTHIA J. STEINOUR, Defendant NOTICE TO DEFEND AND CLAIM 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 will proceed without you and a decree in divorce or annulment may 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, carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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. Court Administrator Fourth Floor cumberland County Courthouse Carlisle, Pennsylvania 17013 . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95- 1135 CIVIL TERM IN DIVORCE THOMAS A. STEINOUR, plaintiff . . v. CYNTHIA J. STEINOUR, Defendant . . COMPLAINT IN DIVORCE 1. plaintiff is Thomas A. steinour, an adult individual currently residing at 60 Hanna Road, Newburg, cumberland county, Pennsylvania. August, 1989. 2. Defendant is Cynthia J. steinour, an adult individual Mr. Steinour has resided at this address since currently residing at 60 Hanna Road, Newburg, Cumberland County, Pennsylvania. Ms. steinour has resided at this address since August, 1989. 3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. plaintiff and Defendant were married on June l7, 1979, in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. plaintiff has been advised of the availability of counseling and the right to request that the court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United states of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that Defendant will, ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. Section 3301(c). COUNT II INDIGNITIES 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Defendant has committed such indignities upon the person of the Plaintiff, the innocent injured spouse, as to make his condition intolerable and life burdensome. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. 3301(a)(6) of the Divorce Code of 1980, as amended. COUNT III ADULTERY 13. Paragraphs 1 through 12 are incorporated herein by reference as if set forth in their full text. 14. Defendant has committed adultery by having sexual relations with a male individual contrary to her wedding vows and the Plaintiff is the innocent and injured spouse. WHEREFORE, Plaintiff requests your Honorable court to enter a divorce pursuant to 23 P.S. section 330l(a) (2). Respectfully submitted, , i , .\ I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING COMPLAINT 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. DATE: J-JI..~/15 ./~Y::tl THO S A. STEINOUR, Plaintiff ,..i, "{ I f LM rJ 1 11- en ~~ 11, - "1 0 :r.: -1 '" () i''''.zo -..: ~'l"' ,41 l!) () Ii) @) U> t::!~" I () :::- I.. <,::,,1_" "t ;S .., l;.~."" , . = (",1-:1':,.,1 S) tr) 0., . ",~, -.- r- :r ,<I' O' L, ~I". <""l . _~ \, jl.1 :.r. W '1 .- 0.' I.. r ~~\Il; rf) j::::li.,. ~ a: I~::J - c6 ~. -.. = elL\ TJ 11 j 'i <:l ~~ ~~ ~ ~~~~ ~ ti "" ~ IoJ ti ii ~"" II Q lid!:) g!l IoJ ~ ~ 0:\0:0 l! < , 1oJ" o I ~ ~~ ~ ~ ~ ~ ,,11) no I oz' I'l - " ~~h ~ ~ ~ ~ ~ < 0: :E ~ - " . . 0: ~ III ~ X W <( . .., W 0 ~ 11) II ~e~'~ ~ I - ~ 06 o IoJ ~ l1. 0( Z Z ~ l1. v < ii: 8 _ x ~ u~~ (!) III U . , ' .., ~L . ' '. ~. ~ THOMAS A. STEINOUR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : CIVIL ACTION - LAW 95-1135 CIVIL TERM CYNTHIA J. STEINOUR, Defendant . . : IN DIVORCE APPIDAVIT OP SI!lRVICB AND NOW, this 22nd day of March, 1995, comes Bradley L. Griffie, Esquire, Attorney for Plaintiff, Thomas A. Steinour, and states that he personally mailed a certified and true copy of a complaint in Divorce and Petition for Exclusive possession to the Defendant, Cynthia J. Steinour, at 60 Hanna Road, Newburg, pennsylvania, by certified and restricted mail, return receipt requested. A copy of said receipt is attached hereto indicating service was made on March 17, 1995. re Sworn and subscribed to this d;J fl.t.l day of Marr:h, 1995. ../;{: I ?JZ i . _ ), { 'L" j h ,J t.IlIa.IalSoal Rcbi1 J. Go6holn. Nctafy NlIIc CarlsIe Ilort>. ClITt1erlariJ C",-'nlV . My C.1Il1iT/Sdcn Expjros AjlrIIl'l. 1!l!l5 ~. ~ Z Db'! 875 518 . ' Receipt for Certified Mail .~ No Insuronco Covoroue Provided -~ ~ 00 1101 USO lor IntOtnDllonal Moil ~ -, .~.. ISuo Reversol ~, '\ .~ ''(S CI') 5.,.,todl Oll "'f "'1. ; 'J ~fl"J""-lt'tlnll'''''IIY't;lJ ~ AIt!lJln"..CtI';I~"'h'V''''l c:s 10 ~';tIO"l ... 0.14' . caflt:IUlllHlJcelf,'C;. ~D.u&,.rlljlt'JII'\' .,., L.d fE 32 CO ... :""_t''''-.;. ~~i~;:;;ii;;!1};;r~~il If'~f\\!~,.c~~.,!~'!'!'?"~~'.~.b';.'J7'(J",j,r"l:"7it2t""'H];"ci",~.'i;;;,t"..., .'elloWlng .eM. C.. 'Jlor. "". '.~tr."r~. ! i. )'1 /'Ml Yout...... iitd ....... on"", ,...,.. 0'''''0,," SO .ha. w. c"'~ "iiI" 'f"'.""'>;1i}"''''J''fl""':ti:~~i:;~E;j. ~ '[Ii f~~;:1~~;~~~~~];'i~:*~~\~~:!i.";~~~~~'=;(1,~1i;1~H;~~~~~f.!~i'ld~~~i;~! ! :.~; ~~.-~ !:.,~;rw~~;'~ ~ .~_~;~th~f~i, :n~;~ t'~.~... ~11~.~W~~~::"~~ .Jf~~?;~..~~\~.~.. ;~~~H.'~~~ti~j;~;~~.;~~;;.i~~'~?I- " I" '.' 'Tht""unt-"IColp...m tIt."'i....horiIlha -....dtl_ and'hod...:I'... .,.~.,..., :''''.' .~" '".."",'lu ! ,;'J 8fdtl_,~",;")'."';' ".'d'O \ lJ:'1:i",.,,..t..,,,,,.,,,...,.,;.,, "',,: '.""", "'. Cen.ull G.tmlller le,.I.e.'S".;", , 1.~.;11in.iA!l/.c/e <l.'.. II. '.cl. ".';t~.''i'. rl.)' 't"-'..,..,.;,.,,-.:,.,.,:,.;;. 7,....'.;..':,' '~..,ArtJcl. Numbo"+""""."'''''',t:'H{,q'(.i l~iirC'i",' ..'iiiD" , ;;f~'f(.i:(]I!rVel! :ZI'()CHIM'.. '~';i/ ...;f!""Si ''''I'~ ''';~v" ,<,1 d'\:: ..~,~..;t;"!'cI 4b.'ServlceTyP8'. "CCi'''',',''ji' ,,,,,,,,,,',,.cj,1 If ~;,:!~:;~';~:i:t;l~~~N ~l(i~~~.~!~ ~' Q ,', '.d... ',: '. ...", ".,"". .,i" 7, D.l. 01 D.I/~.,v" 'i" ';.,...,.." .II, '0 v' .!..'~'~'f:\:~._~., .c-}"':!. .....~.<....,. ..... .. "-J::? 17-' .. 'hd,.,:.,", i' :\. ?/i ""';..c;. .... '-;.'j",-. ' . \..... ~ .. '.';~".';:.' tlil 6,' .el..;x .8:. Add........ Add,... (OnIV II requO.I.d'1; r '. ..'. .nd lea I. po/dl . '."".:. i I.:.~ ..' ../gn,~l)"e .. . .. '" """.: " is - - , ~l . ' I;,;t~~?~ *u.& ClI'Ol '''''''1-114 DOMESTIC. RETURN RECEIPT'.' L.:,..;._..,.-..~.._ .\',,_. ....'...., ',', ,;..:..".,... . I \ I t " 1/ .,.,. ..n = e:>- M r-i .;-,.... .r >_ l~'~ :":;-,1.1. ~~; ~;.~. ..~ -~';~ r ..... ..... = .. = .) ",'11", 51"- '-'U ,~ -' ~ . I . ~, ' . . " .-.........-..... - -::~~-=:-:::-:. ~~. VB. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW I; I '. t THOMAS A. STEINOUR, Plaintiff CYNTHIA J. STEINOUR, Defendant 95-1135 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under section 3301 (c) of the Divorce Code was filed on March 3, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in counseling, and that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa. C.S. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: " / ..,.' , ---- ,) '}"<5 /~ ,/,1 _/ ' // /1 ; /' .~I .' /' /.j'--L-- ,,' ._'/~ .7'_.. _. /'/ ,; . ( t,/~'-'-':;,,'" ~:'".:.'-'/~..I~ ../y/~,/ ':.-#~ C~NTHIA J. STEINOUR, Defendant LJ") <7> :c a- <1:1 ,.... f.:~;::f -,'; ;'~: 'a~~'l '" ::- :;".. "'~ ..~ ('oJ ,n ,~~;\-j . 'I'" -' :=> ..-, ~.., ;.~ THOMAS A. STEINOUR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW CYNTHIA J. STEINOUR, Defendant : 95-1135 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301 (c) of the Divorce Code was filed on March 3, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree of Divorce. 4. I have been advised of the availability of marriage counseling, that I may request that the Court require that my spouse and I participate in counseling, and that the Court maintains a list of marriage counselors in the prothonotary's Office, which list is available to me upon request. Being so advised, I decline to request that the Court require that my spouse and I participate in counseling. 5. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa. C.S. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ~~~ TH S A. STEI OUR, Plaintiff DATE: 7/3l:;) Ion a'I ,. ~ :c n- '" " . N ('-I ,. ,j" , -' " , '" : -, . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL A~ON - LAW 95- , /3) CIVIL TERM IN DIVORCE THOMAS A. STEINOUR, plaintiff vs. CYNTHIA J. STEINOUR, Defendant AND NDW, thi.qf..-day D and consideration of the wit 1995, upon presentation a Rule is hereby issued upon the Defendant, cynthia J. steinour, to show cause, if any she has, as to why exclusive possession of the parties' residence at 60 Hanna Road, Newburg, Cumberland county, pennsylvania, should not be granted to the Plaintiff pending further Order of Court. Rule returnable at ()10 day of 14 td Courtroom No.....3 of a hearing to be held on 1t1ldi!.J/J..I.(, the , 1995, at /.'.30 o'clock -I.m., in the Cumberland county courthouse, Carlisle, Pennsylvania. service to be made by certified mail, restricted delivery upon the Defendant. J. \' -'-1',"',;' ).J'!r,'~J ':\ ,- "'.1".1':,;,;;, 'iDi.l' . ~ i _' I \,'''1 ;\1 56. \:~ /.1 G 0 I U1H THOMAS A. STEINOUR, plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95- II}')' CIVIL TERM IN DIVORCE vs. CYNTHIA J. STEINOUR, Defendant PETITION FOR EXCLUSIVE POSSESSION AND NOW, comes plaintiff, Thomas A. Steinour, by and through his counsel of record, Bradley L. Griffie, Esquire, and petitions the court as follows: 1. Your Petitioner is Thomas A. steinour, the above named Plaintiff in the divorce action initiated contemporaneously with the filing of the within petition for Exclusive possession and an adult individual currently residing at 60 Hanna Road, Newburg, cumberland County, Pennsylvania. 2. Your Respondent is cynthia J. Reed, the above named Defendant and an adult individual currently residing at 60 Hanna Road, Newburg, Cumberland County, pennsylvania. 3. The parties have resided at the residence located at 60 Hanna Road, Newburg, cumberland county, PennSYlvania, since August, 1989. 4. Petitioner has been and continues to be the primary financial caretaker for the parties and their four children, namely: Michael R. steinour, born May 10, 1980; Megan L. steinour, born May 19, 1982; Katharine J. steinour, born May 8, 1988; and Robert B. steinour, born September 18, 1992. 5. Respondent has vacated the parties' marital residence in the past for brief periods of time. 6. The Respondent has advised the petitioner that she will not engage in any type of marital counseling and, further, that she believes, as far as she is concerned, that the parties are separated and they can proceed with their lives accordingly. 7. Petitioner is primarily responsible for taking care of the children in the morning prior to their attendance at school and is primarily responsible for them following Petitioner's return from work in the evening and on weekends. 8. The youngest child, who is not of school age, is taken to a baby-sitter during the day while petitioner is working. 9. The Respondent is not gainfully employed despite Petitioner's desire that she secure some type of gainful employment. 10. The parties have slept in different beds for an extended period of time. 11. Respondent has an alcohol problem, which problem has been increasingly evident. 12. Respondent's alcohol problem has had a limited impact upon the children to date, but Petitioner believes that her increasing alcohol abuse problem will begin to have greater impact upon the children. 13. The Respondent has been violent with the Petitioner, punching him, throwing a crock-pot at him and otherwise being belligerent toward the Petitioner. 14. The Petitioner believes that the Respondent is making numeroUS attempts to provoke the Petitioner lnto some type of physical confrontation in order to gain some type of leverage in the parties' pending divorce, or their present sit~ation of being separated. 15. Respondent has been engaged in multiple affairs with individuals other than her husband and has insisted upon the petitioner engaging in such affairs. 16. The parties' eldest son has been determined to be subject to attention deficit disorder and is in need of strong stability and parental attention which can only be provided by the petitioner. 17. While the Respondent has refused to become gainfully employed, she is completely able to be gainfully employed and to care for her financial needs. 18. The Respondent's family resides in the area and can easily provide financial assistance or otherwise provide housing assistance to allow the tension that is being created in the marital residence to be lifted with the Respondent leaving the residence. 19. While petitioner believes he has been able to shield the parties' four children from the disruption and physical, verbal and mental abuse of the Respondent, petitioner believes that the Respondent's increased alcohol abuse and violent nature is beginning to have an impact upon the parties' children. 20. In order for the petitioner to continue to provide for the financial and material needs of the parties' children, Petitioner needs to have the knowledge that he will return each evening to the children's residence without the possibility of being physically, mentally, verbally or emotionally accosted by Respondent, particularly in the presence of the children. WHEREFORE, Petitioner requests your Honorable Court to enter an Order providing him with exclusive possession of the parties' residence at 60 Hanna Road, Hanna, Cumberland county, Pennsylvania. Respectfully submitted, E & ASSOCIATES L. Griffie, Esquire rney for Petitioner o North Hanover street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 . _. ,...,..___.__.....-- .' __:~::l..:_:-;:~.=.~,,- .." ,I I' (I !. I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein , 1 I i. I I I are made subject to the penalties of 18 Pa.C.S. section 4904, relating to unsworn falsification to authorities. DATE: .) I {}7/9C; ~/U.$ THOMAS A. STEINOUR ~ C)..' ---. . ","\ "' M- (ij '.... :i ~ .J ~ R' ;1 H Ul lfl Ul ~ .. '" ~ ... ti 0 .... .u I- ... ~~ .... ~i ~ ~ ~ !'l ... ~ ,.-I ~ .u U j II 0 ~ 0( ~ ~~~ l: o I ..." "Ul 0. ~'.-I ~ ~ 1 ~ :( 8~ !5.... oz' ~~ Ul Z 0. l'l - " 0( II ~~I~ ~~ .. 0( iJ ~ :i ~ l(l ~ J: .. , x Ul . e 1: ~ Ul Ii 5 ~ ~ w 0 Ii ~ ~i~U~ - I: 06 o m . LL 0( Z Z % . .. ~ 8 of 0( < ; _ x I u ~ ~ ~ ~ c> N ~~ ~~ .~ ~ j . ., " , :. , '"''"11''&0'''''''.'''''''.''''' ~....o.o,.".,.,""'I"'lnlll'" " ; ,